ML20052B170
| ML20052B170 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/27/1982 |
| From: | Mizuno G, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| Shared Package | |
| ML20052B165 | List: |
| References | |
| NUDOCS 8204300110 | |
| Download: ML20052B170 (6) | |
Text
4/27/82 UNITED STATES OF AMERICA 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 AUTHORITY
)
)
(Clinch River Breeder Reactor Plant)
NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC., AND THE SIERRA CLUB TENTH SET OF INTERR0GATORIES_ TO NUCLEAR REGULATORY COMMISSION STAFF Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Comission Staff (Staff) hereby updates its June 18, 1976 and August.10, 1976 responses to Intervenors' Natural Resources Defense Council, Inc. and the Sierra Club Tenth Set of Interrogatories to the Nuclear Regulatory Comission filed on May 13, 1976. Attached hereto are the Staff's answers to NRDC's and the Sierra Club's interrogatories, together with the affidavits of Mr. Erickson and Mr. Nehemias who provided the answers.1/
On March 4, 1982, the parties in this proceeding developed a Protocol for Discovery. NRDC has requested that answers to interrogatory questions be provided in six parts. The following six parts are:
A)
Provide the direct answer to the question.
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-1/
The affidavits of Mr. Erickson and Mr. Nehemias are unsigned. However, a copy of their signed,' notarized affidavit will be filed shortly.
820430dp i
B)
Identify all documents and studies, and the particular parts thereof, relied upon by the Staff, now or in the past, which serve as the basis for the answer.
In lieu thereof, at Staff's option, a copy of such document and study may be attached to the answer.
C)
Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (b).
In lieu thereof, at Staff's option a copy of each such document and study may be attached to the answer.
D)
Identify by name, title and affiliation the primary Staff employee (s) or consultant (s) who provided the answer to the question.
E)
Explain whether the Staff is presently engaged in or intends to engage in any further, ongoing re:earch program which may affect the Staff's answer. This answer need be provided only in ca:es where the Staff intends to rely upon on-going research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR. Failure to provide such an answer means that the Staff does not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.
F)
Identify the expert (s), if any, which the Staff intends to have testify on the subject matter questioned, and state the qualifica-tions of each such expert. This answer may be provided for each separate question or for a group of related questions. This answer need not be provided until the Staff has in i
fact identified the expert (s) in question or determined that no expert will testify, as i
long as such answer provides reasonable notice to Intervenors.
l For all the responses to interrogatories in this set the following l
are the answers to the requested parts in the Protocol for Discovery.
B)
All documents and studies, and the particular parts thereof, relied upon by the Staff now or in the past which serve as the basis for the I
answer are mentioned in the direct answer to the question unless otherwise noted.
i
. C)
There were no principal documents and studies specifically examined but not cited in (b) unless otherwise noted.
D)
The name, title and affiliation of the Staff employee (s) or consultant (s) who provided the answer to the question are available in the affidavits.
E)
The Staff is not presently engaged in nor intends to engage in any further, on-going research program which may affect the Staff's answer unless otherwise noted.
F)
At this time, the Staff has not determined who' will testify on the subject matter questioned.
Reasonable notice will be given to all parties after the. Staff has made this determination.
At that time, a statement of professional qualifications will be provided for each I
witness.
In the April 14, 1982 Order Following Conference With Parties, the Licensing Board renumbered NRDC's contentions. When an old contention number appears in the interrogatory question or answer, the new conten-tion number will be indicated in parentheses.
Respectfully submitted, ha
/
Daniel T. Swanson Counsel for NRC Staff D.
Geary. Mizuno Counsel for NRC Staff Dated at Bethesda, Maryland this 27 day of April,1982
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NRC STAFF'S ANSWERS TO NRDC'S AND j.
THE SIERRA CLUB'S INTERR0GATORIES
.The NRC Staff has determined that previous responses to -
. interrogatories I.,-#1 and #2; II. #1 and #2; III, #1 through #8 and in the section entitled "The following interrogatories are.related to Contention 14" #2 and #3 are still. applicable and need no updating.
2
. In interrogatory #2 pertaining to Contention 14 (renumbered as 8),
.2 mrem /kw should be.2 mrem / hour.
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d UNITED STATES OF AMERICA 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 AUTHORITY (Clinch River Breeder Reactor Plant) )
AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Health Physicist, Radiological Assessment Branch, Div', ion of Systens Integration, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering Interrogatories #1 and #2 of Section I; #1 and #2 of Section II and #1 through #8 of i
Section III of the 10th Set and I hereby certify that the answers given are true to the best of my knowledge.
John V. Nehemias Subscribed and sworn to before me l
this day of April, 1982.
l Notary Public j
My Commission expires:
UNITED STATES OF AMERICA 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 AUTHORITY (Clinch River Breeder Reactor Plant) )
AFFIDAVIT OF PETER B. ERICKSON I, Peter B. Erickson, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Project Manager, Standardization and Special Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering Interrogatories #2 and #3 pertaining to Contention 14 (renumbered as 8) of the 10th Set and I hereby certify that the answers given are true to the best of my knowledge.
Peter B. Erickson Subscribed and sworn to before me this day of April,1982.
Notary Public My Commission expires:
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