ML20052B747

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Update to 770113 Response to NRDC & Sierra Club 760916 Thirteenth Set of Interrogatories
ML20052B747
Person / Time
Site: Clinch River
Issue date: 04/29/1982
From: Swanson D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
National Resources Defense Council, Sierra Club
Shared Package
ML20052B744 List:
References
NUDOCS 8205030528
Download: ML20052B747 (3)


Text

4/29/82 4

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 4

Plant)

)

NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB THIRTEENTH SET OF INTERR0GATORIES TO THE NUCLEAR REGULATORY C'"iMISSION STAFF Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Cormission Staff (Staff) hereby updates its January 13, 1977 response to Intervenors' Natural Resources Defense Council, Inc. and the Sierra Club Thirteenth Set of Interrogatories to the Nuclear Regulatory Commission Staff filed on September 16, 1976.

Attached hereto are the NRC Staff's answers to NRDC's and the Sierra Club's interrogatories, together with the affidavit of Mr. Bill M. Morris. _1f Respectfully submitted,

,7

,, A/ ? $<*>v Daniel T. Swanson Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of April,1982 1/ The affidavit of Mr. Morris is unsigned. However, a copy of his signed and notarized affidavit will be filed shortly.

82050305d

< NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S INTERROGATORIES The Staff defers responding to these questions in this set until after the issuance of the SER for the CP.

These questions deal with details of the safety review which is not complete. Until the safety review is finished, these details cannot be furnished.

In my view, these questions involve aspects of Contentions 1, 2, and 3 which have been deferred by the Board during its April 20, 1982 prehearing conference.

1 4

I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY

)

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #54 of the 13th Set and I hereby certify that the answers given are true to the best of my knowledge.

BILL M. MORRIS Subscribed and sworn to before me this day of April,1982.

Notary fulilic

_My Commission expires: