ML20042A245

Request for Production of Documents

ML20042A245
Person / Time
Site:	Clinch River
Issue date:	03/18/1982
From:	Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20042A222	List: ML20042A221 ML20042A226 ML20042A230 ML20042A234 ML20042A239 ML20042A245 ML20042A253
References
NUDOCS 8203230242
Download: ML20042A245 (3)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '02 l17 }8 M:32 ATOMIC SAFETY AND LICENSING BOARD P

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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 )

PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB FIRST REQUEST TO STAFF 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 Staff provide at the Commission's office at 1717 " H " S tr ee t , N.W., Washington, D.C. copies of the f ollowing documents.

General

1. Provide a complete current version of the General.

Design Criteria which Staf f believes is applicable to 8203230242 820318 PDR ADDCK 05000537 0 PDR

2 the CRBR, to the extent it differs from the criteria set forth in Appendix A to the 1977 Staff Site Suitability Report. Identify whether it reports Final or Draf t Criteria.

2. Provide copies of all documents and other materials provided to Staff by Applicants, since April 23, 1977, relating to meetings held between Applicants and Staff to review and discuss Applicants' PSAR and other matters in the CRBR LWA and CP application. This request is a continuing one, and applies to all documents and materials provided at all such future meetings.3/

Contention 8

1. Please produce all documents, all staff proposals, and all staff documents submitted to the Commission at the time the Commission was considering the present regulations under 10 CFR S 20.1(c) with regard to the ALARA requirement.

1/ Intervenors believe a formal request for production of such Hocuments and materials is necessary since an informal request by Intervenors to Staff on March 10, 1982 for such documents and materials was categorically denied. Intervenors believe that such a denial is in contravention of the Board's directive during the February 9-10, 1982 Prehearing Conference that the parties cooperate in' formally to the greatest extent possible and make full use of information presented during the ongoing review meetings between Staff and Applicants.

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2. Provide all written correspondence, prepared since April 23, 1977, between Staff and the Environmental Protection Agency that provides NRC Staff's opinion with regard to the establishment of new occupational dose limits as proposed in drafts and proposed rules by the EPA during the last four years.

Respectfully submitted,

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Elfyn R. Weiss L ' l HARMON & WEISS 1725 Eye Street, N.W.

Washington, D.C. 20006 (202) 833-9070 A .

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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 the Sierra Club Dated: March 18, 1982 Washington, D.C.