ML20052B151
| ML20052B151 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/28/1982 |
| From: | Bradley Jones, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| Shared Package | |
| ML20052B140 | List: |
| References | |
| NUDOCS 8204300082 | |
| Download: ML20052B151 (9) | |
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4/28/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB REQUEST TO APPLICANTS AND STAFF FOR ADMISSIONS DATED SEPTEMBER 16, 1976 The Nuclear Regulatory Comission Staff (Staff) hereby updates its February 16, 1977 response to the Natural Resources Defense Council, Inc. (NRDC) and the Sierra Club Request for Admissions filed on September 16, 1976. Attached hereto are the Staff's answers to NRDC's and the Sierra Club's request for admissions, together with the affidavit of those individuals who participated in answering the admissions.1/
In the April 14, 1982 Order Following Conference with Parties, the Licensing Board renumbered NRDC's contentions. When an old contention
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The affidavits of Mr. Robert J. Dube and Mr. Cardis L. Allen are unsigned. However, a copy of their signed, notarized affidavit will be filed shortly.
l 00M 82043
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I number appears in the request for admission or answer, the new contention number will be indicated in parentheses.
Respectfully submitted, 9
i Daniel T. Swanson Counsel for NRC Staff A
b GMb Bradley W. Jones i
Counsel for NRC Staff Dated at Bethesda, Maryland this 28 day of April, 1982.
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I NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S REQUEST FOR ADMISSIONS The NRC Staff has determined that previous responses to request for admissions #31 through #80 concerning contention 2 (renumbered as 1) are still applicable and need no updating.
Contention 2 (renumbered as 1)
Statement 6 The probability of a CDA being initiated by sabotage conducted by one or two in:iders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, is greater than the probability of a design basis accident in an LWR.
Statement 7 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, is greater than the probability of a LOCA in an LWR.
Statement 8 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose famflieswereheldhostagetherebycoercedbyoutsidersisgreaterthan 10' per reactor year of operation.
Statement 9 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose 10glieswereheldhostagetherebycoercedbyoutsidersisgreaterthan fan per reactor year of operation.
Statement 10 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose
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famflieswereheldhostagetherebycoercedbyoutsidersisgreaterthan 10~ per reactor year of operation.
Statement 11 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders is less than the probability of a design basis accident in an LWR.
Statement 12 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, is less than the probability of a LOCA in an LWR.
Statement 13 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose famflieswereheldhostagetherebycoercedbyoutsiders,islessthan 10' per reactor year of operation.
Statement 14 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain ar ass to vital equipment, or by a group of outsiders aided by one or twe insiders, or by insiders whose famflieswereheldhostagetherebycoercedbyoutsidersislessthan 10~ per reactor year of operation.
Statement 15 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose famflies were held hostage thereby coerced by outsiders is less than 10- per reactor year of operation.
Statement 16 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be greater than the probability of a design basis accident in an LWR.
4 Statement 17 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be greater than the probability of a LOCA in an LWR.
Statement 18 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders may be greater than 10-6 per reactor year of operation.
Statement 19 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders may be greater than 10-5 per reactor year of operation.
Statement 20 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders may be greater than 10-4 per reactor year of operation.
Statement 21 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be less than the probability of a design basis accident in an LWR.
Statement 22 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be less than the probability of a LOCA in an LWR.
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Statement 23 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be less than 10-6 per reactor year of operation.
Statement 24 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be less than 10-5 per reactor year of operation.
Statement 25 The probability of a CDA being initiated by sabotage conducted by one or two insiders who could gain access to vital equipment, or by a group of outsiders aided by one or two insiders, or by insiders whose families were held hostage thereby coerced by outsiders, may be less than 10-4 per reactor year of operation.
Statement 26 The Applicant is unable to make a determination that the probability of a CDA being instituted by sabotage conducted by one or two insiders who could gain access to vital equipment, or by insiders whose families were held hostage thereby coerced by outsiders is less than the probability of a design basis accident in an LWR.
Statement 27 The Applicant is unable to make a determination that the probability of a CDA being instituted by sabotage conducted by one or two insiders who could gain access to vital equipment, or by insiders whose families were held hostage thereby coerced by outsiders is less than the probability of a LOCA in an LWR.
l Statement 28 i
The Applicant is unable to make a determination that the probability of a CDA being instituted by sabotage conducted by one or two insiders who could gain access to vital equipment, or by insiders whosefagilieswereheldhostagetherebycoercedbyoutsidersisless than 10- per reactor year of operation.
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Statement 29 The Applicant is unable to make a determination-that the probability of a CDA being instituted by sabotage conducted by one or two insiders who could gain access to vital equipment, or by insiders whosefagilieswereheldhostagetherebycoercedbyoutsidersisless than 10- per reactor year of operation.
Statement 30 The Applicant is unable to make a determination that the probability of a CDA instituted by sabotage conducted by one or two insiders who could gain access to vital equipment, or by insiders whose famflieswereheldhostagetherebycoercedbyoutsidersislessthan 10- per reactor year of operation.
Response to #6 through #30 The Staff can neither admit nor deny these statements. The Staff does not believe that it is possible to quantify the probability of successful acts of sabotage nor does the Staff believe that such determi-R nations are necessary to insure public health and safety. We have stated this in response to previous interrogatories.
In evaluating the adequacy of protection against sabotage the Staff relies on, as a minimum, the requirements contained in applicable portions of the Commission's regula-i tions. The Staff will also, in its review of the CRBRP, exercise its independent judgment in evaluating these requirements and the need for l
any additional safeguards provisions. As reported in Section 7.3 of the FES the staff has evaluated the potential environmental impacts associated with acts of sabotage directed at the CRBRP and has concluded that they are minimal. The basis for this conclusion rests on the margin of pro-l tection offered by an effective safeguards system, the protective features of the plant associated with its safety design basis which provide inherent resistance to acts of sabotage, and the absence at this time of any evi-l dence which would indicate a significant threat to nuclear facilities.
UNITED STATES OF AtERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTil0RITY
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(Clinch River Brecdcr Rehctor
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Plant)
AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:
1.
I an employed by the U.S. Nuclear Regulatory Commission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safecuards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.
2.
I am duly authorized to participate in answering the Request for Admissions pertaining to Contention 2 (renumbered as 1) #6 through 30 and I hereby certify that the answers given are true to the best of my knowledge.
ROBERT J. DUBE
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Subscribed and swnrn to before me l
this day of April, 1982.
i Notary Public
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My Cornission expires:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
In the Matter of UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )
AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering the Requests for Admissions pertaining to Contention 2 (renumbered as 1), #31 through #80 and I hereby certify that the answers given are true to the best of my knowledge.
Cardis L. Allen Subscribed and sworn to before me this day of April,1982.
Notary Public My Commission expires:
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