ML20042A239
| ML20042A239 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 03/18/1982 |
| From: | Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club |
| To: | JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| Shared Package | |
| ML20042A222 | List: |
| References | |
| NUDOCS 8203230236 | |
| Download: ML20042A239 (6) | |
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~}.zrr UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'82 g.]g 7 P3:31 ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.
Dr. Cadet H. Hand, Jr.
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In the Matter of
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Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY
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PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
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NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND THE SIERRA CLUB FIFTH REQUEST TO APPLICANTS FOR PRODUCTION OF DOCUMENTS Pursuant to 10 CFR S 2.741, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, request that Applicants provide at the office of their Counsel in Washington, D.C. copies of the following documents.
Contentions 5 and 9 I
1.
To the extent not covered in updated Question 7 in i
Intervenors' First Set of Interrogatories to Applicants, provide all documents in the possession of
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2 Applicants that assess the adequacy of physical security and materials accounting and control at DOE f acilities, NRC-licensed facilities, or DOD domestic and foreign facilities, except the following:
1.
" Improvements Needed in the Programs for the Protection of Special Nuclear Material" (11/7/73) ;
2.
" Protecting Special Nuclear Material In Transit:
Improvements Made and Existing Problems" (4/12/74);
3.
Letter To chairman, Atomic Energy Commission, re:
Security at commercial nuclear powerplants (10/ 16/74);
4.
Unclassified summary of a classified report entitled, " Shortcomings in the Systems Used To Control and Protect Highly Dangerous Nuclear Mater ia l" (7/22/76);
5.
Unclassified summary of a classified report entit led, " Safety and Transportation Safeguards at Rocky Flats Nuclear Weapons Plant" (1/11/77) ;
6.
" Security at Nuclear Powerplants--At Best, Inadequate" (4/7/77) ;
7.
Unclassified summary of a classified report entitled, " Commercial Nuclear Fuel Facilities Need Better Security" (5/2/77) ;
8.
Letter to Chairman, John Dingell, U.S. House of Representatives, re:
Unaccounted for nuclear material ~(5/5/78) ;
3 9.
Letter to Secretaries of Energy and Defense, re:
Transportation of nuclear weapons (8/1/79);
10.
" Nuclear Fuel Reprocessing and the Problems of Safeguarding Against the Spread of Nuclear Weapons" (3/18/80) ;
11.
Letter to Rep. Tim Wirth, re:
Alleged missing material from DOE's Rocky Flats weapons production plant (10/1/80) ;
12.
Unclassified summary of a classified report entitled, " Security of U.S. Nuclear Weapons Overseas--Where Does it Stand?" (11/3/80) ;
13.
" Accountability and Control of Warheads in the Custody of the Department of Defense and the Energy Research and Development Administration" (6/2/77) ;
14.
Letter to Senator John Glenn, re:
Assessment of various aspects of U.S. nuclear safeguards programs (2/19/80) ;
15.
Lcccer to Rep. John D.
Dingell, re:
Report on
" Nuclear Diversion in the U.S.?
13 Years of Contradiction and Confusion." (2/27/79);
16.
" Role of the International Atomic Energy Agency in Safeguarding Nuclear Material" (7/3/75) ;
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Contention 8 1.
Provide the f ollowing document:
" Organization for Radiation Protection", Lauriston S. Taylor, DOE / TIC-10124, date unknown.
2.
Provide all written correspondence, prepared since April 23, 1977, between Applicants and the Environmental Protection Agency that relates to Applicants' opinion with regard to the establishment of new occupational dose limits as proposed in draf t and proposed rules by EPA during the last four years.
Contentions 9, 10, and 17 1.
Provide all documents prepared since April 23, 1977 by Department of Energy (D0E) or its contractors, including but not limited tc DuPont, Inc., that discuss the technical performance, reliability, maintainability, licensability. safety, environmental acceptability or economic feasibility of the Barnwell, S.C.
reprocessing facility, including, but not limited to:
a.
whether the Barnwell f acility will function as designed; b.
whether DOE should purchase the f acility.
2.
Provide all documents prepared or received by the U.S.
government since April 23, 1977 relating to inquiries
5 made by the U.S. government to any foreign government, including but not limited to the United Kingdom, regarding the purchase, or otherwise obtaining by the U.S. of plutonium from foreign government (s).
6 i
Respectfully submitted, EA A %h /2 2%6.Ar%")
Ellfh R. Weiss
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HARMON & WEISS 1725 Eye Street, N.W.
Washington, D.C.
20006 (202) 833-9070 lW h=-y _ ea Barbara A.
Finamore S. Jacob Scherr Natural Resources Defense Council, Inc.
1725 Eye Street, N.W.
Washington, D.C 20006 (202) 223-8210 Attorneys for Intervenors Natural Resources Defense Council, Inc.
and tne Sierra Club Dated:
March 18, 1982 Washington, D.C.
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