ML20052B752

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Update to 760128,0407,0616,1119 & 1201 Response to NRDC & Sierra Club 751231 Third Set of Interrogatories
ML20052B752
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 8205030533
Download: ML20052B752 (3)


Text

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4/29/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of U.S. DEPARTMENT OF ENERGY

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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 THIRD SET OF INTERROGATORIES TO NUCLEAR REGULATORY COMMISSION STAFF Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Commission Staff (Staff) hereby updates its January 28, 1976, April 7, 1976, June 16, 1976, November 19, 1976 and December 1,1976 response to Intervenors' Natural Resources Defense Council Inc. and the Sierra Club Third Set of Interrogatories to the Nuclear Regulatory Commission Staff filed on December 31, 1975.

Attached hereto are the Staff's answers to NRDC's and the Sierra Club's interrogatories, together with the affidavit of Mr. Howard B. Holz.1/

Respectfully submitted, b oxA/ Y Daniel T. Swanson Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of April,1982 1/

The affidavit of Mr. Holz is unsigned. However, a copy of his signed and notarized affidavit will be filed shortly.

920s0.305551

4 NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S INTERR0GATORIES For the interrogatories in Sections I and II, the NRC Staff defers updating these questions until after the CP SERbecause the Staff has not yet selected the computer codes and other tools it will use in its audit and evaluation. In my view,' these questions involve asoects of Contentions 1, 2, and 3 which were deferred by the Board during its April 20, 1982 prehearing conference.

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I 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

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TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF HOWARD B. HOLZ I, Howard B. Holz, being duly sworn, state as follows:

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I am employed by the U.S. Nuclear Regulatory Commission as a Systems Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

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I am duly authorized to participate in answering Interrogatories #1 through #15 of Section I and #1 through #30 of Section II of the 3rd Set and I hereby certify that the answers given are true to the best of my knowledge.

Poward B. Holz Subscribed and sworn to before me this day of April, 1982.

Notary Public My Commission expires: