ML20052B760
| ML20052B760 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/29/1982 |
| From: | Bradley Jones, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| Shared Package | |
| ML20052B744 | List: |
| References | |
| NUDOCS 8205030539 | |
| Download: ML20052B760 (22) | |
Text
4/29/82 J
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
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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 EIGHTH SET OF INTERR0GATORIES TO NUCLEAR REGULATORY COMMISSION STAFF l
Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Commission Staff (Staff) hereby updates its July 15, 1976 and November 12, 1976 responses to Intervenors' Natural Resources Defense Council, Inc. and the Sierra Club Eighth Set of Interrogatories to the Nuclear Regulatory Commission Staff filed on May 7, 1976. Attached hereto are the Staff's answers to NRDC's and the Sierra Club's interrogatories, together with the affidavits of those individuals who participated in answering the interrogatories. If The NRC Staff has determined previous interrogatory responses to
- I.1 through #I.4 and #VII-1 through VII-5 are still applicable and need no updating.
On March 4,1982, the parties in this proceeding developed a Protocol for Discovery.
NRDC has requested that answers to interro-gatory questions be provided in six parts. The following six parts are:
_11 The affidavits of Mr. Allen, Mr. Dube and Mr. Swift are unsigned.
However, a copy of their signed and notarized affidavits will be filed shortly.
820503053"'
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1 A)
Provide the direct answer to the question.
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 particu-lar 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 intend to engage in any further, on-going research program which may affect the Staff's answer. This answer need be provided only in cases where the Staff intends to rely upon ongoing 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 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 qualifications 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 fact identified the expert (s) in question or determined that no expert will testify, as long as such answcr provides reasonable notice to Intervenors.
For all the responses to interrogatories in this set the following 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 answer are mentioned in the direct answer to the question unless otherwise noted.
C)
There were no principal documents and studies specifically examined but not cited in (b) unless otherwise noted.
t 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 unless otherwise noted.
E)
The Staff is not presently engaged in nor intends to engage in any further, on-going research pro-gram 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 qualifica-tions will be provided for each 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 contention 4
number will be indicated in parentheses.
Respectfully submitted,
/)wUl/nww Daniel T. Swanson Counsel for NRC Staff
/
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%3
.y Gradley W. Jones Counsel for NRC Staff Dated at Bethesda, Maryland this 29th day of April,1982
NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S INTERR0GATORIES II. The following interrogatories are related to Contention 4 (renumbered as 3):
Interrogatory 1 Identify and describe all the accident sequences (scenarios) identified in the course of the Reactor Safety Study that were previously unknown but which turned out to have probabilities and consequences that were considered significant.
By significant here we mean that the estimated event probabilities were explicitly considered in the calculations.
Interrogatory 2 Identify and describe all the accident sequences (scenarios) identified in the course of the Reactor Safety Study that were previously thought to be less significant (in terms of probability of consequences), relative to DBAs considered in typical BWR and PWR Safety Analysis Reports at the time the Reactor Safety Study was initiated, but that turned out to be equally significant or more significant than the DBAs considered at the time.
Interrogatory 3 Doesn't the Staff agree that similarly significant event sequences could be uncovered if a "Rasmussen" type analysis were performed on the CRBR?
Interrogatory 4 If the Staff disagrees with (3) above, explain in detail the basis for the Staff's disagreement.
Interrogatory 5 Has, or is, the NRC considering study of the LMFBR along the lines of the Reactor Safety Study?
If so, please describe fully the consideration given to such a study by the NRC.
Interrogatory 6 Is the Staff aware of any suggestions or recommendations by employees of ERDA, EPRI, or the national laboratories, by NRC consultants or any other nuclear reactor safety experts, that a "Rasmussen" type study be made of the LMFBR?
If so, please identify each such suggestion or recommendation.
2 Interrogatory 7 Please describe fully in detail the procedures utilized by the Staff to assure itself that there are no accident sequences (scenarios) of greater consequence than the CRBR DBAs considered by the Applicant in the PSAR; that the DBAs considered will envelop the entire spectrum of credible accident initiators, sequences and scenarios.
Response to Interrogatories #1 through #7 A)
The procec'ures used by the Staff to assure itself that the acci-dent sequences and consequences have been properly considered in the design are as follows: The review is divided up among specialists in various fields (containment systems, fuels and materials, mechanical, core performance, auxiliary systems, etc.).
Each specialist examines the reactor system and the Applicant's evaluation of the design for his area of responsi-bility, using experience with LWR's engineering evaluation in general, and independent calculations as appropriate to identify circumstances that could reasonably be expected to lead to accidents. All scenarios are considered unless it is deter-mined that they have trivial consequences or extremely low probability of occurrence, or that their consequences are bounded by some scenario already considered.
For the Clinch River Breeder Reactor Plant (CRBRP) we are examining a large number of phenomena and potential core disruptiveaccident(CDA) initiators. The initiators include reactivity additions ranging from a few cents to a few dollars per second, step reactivity insertions, loss of coolant flow, loss of heat sink and fuel failure propagation among others.
Among the phenomena being examined we have included:
fuel l
1 failure mechanisms, fuel relocations, thermal interaction of fuels and other materials with coolant and structrures as well as potential recriticality conditions.
This review effort is more than adequate to provide a basis for judging that it is feasible to construct and operate a reactor of this general size and type on the CRBR site.
The Applicant has begun a Probabilistic Risk Assessment of the proposed CRBR which will provide further information on accident initiators, sequences and scenarios, later in the licensing process. We expect to review this Probabilistic Risk Asse sment thoroughly. The Reactor Safety Study (WASH-1400) did indeed identify some accident sequences as being more significant than previously thought, and it is possible that the Probabilistic Risk Assessment of the CRBR will make similar discoveries.
III. The following interrogatories are related to Contention 5 (renumbered as 4):
With respect to the initiation of an accident at the CRBR:
Interrogatory 1 Would it be possible for one insider, acting alone, to initiate a TOP accident without scram, at the CRBR? Explain to detail the basis for the answer.
Response
A)
The Staff does not review every sabotage scenario during the FES (EIS) review. We do, however, recognize that radiological l
i
!~
1 sabotage by a single person, including an insider, is possible and therefore have promulgated regulations requiring the design of the safeguards systems to protect against acts of radiological sabotage, 10 C.F.R. 5 73.1(a).
D)
John W. Hockert, Senior Safeguards Scientist, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards and Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
Interrogatory 2 Would ie be possible for two insiders in collusion, to initiate a TOP accident without scram, at the CRBR? Explain in detail the basis for the answer.
Response
A)
The Staff does not review every sabotage scenario during the FES(EIS) review. We do, however, recognize that radiological sabotage by a single person, including an insider, is possible and therefore have promulgated regulations requring the design of the safeguards systems to protect against acts of radio-logical sabotage, 10 C.F.R. 73.1(a).
D)
John W. Hockert, Senior Safeguards Scientist, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Harvey B. Jones, Jr., Safeguards Analyst, Division of
. Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
Interrogatory 3 Would it be possible for one insider, acting alone, to initiate a LOF accident without scram, at the CRBR? Explain in detail the basis for the answer.
Response
A)
The Staff does not review every sabotage scenario during the FES (EIS) review. We do, however, recognize that radiological sabotage by a single person, including an insider, is possible and therefore have promulgated regulations requiring the design of the safeguards systems to protect against acts of l
radiological sabotage, 10 C.F.R. % 73.1(a).
D)
John W. Hockert, Senior Safeguards Scientist, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
Interrogatory 4 Would it be possible for two insiders, acting in collusion, to initiate a LOF accident without scram, at the CRBR? Explain in detail the basis for the answer.
Response
A)
The Staff does not review every sabotage scenario during the FES (EIS) review. We do, however, recognize that radiological 1
- sabotage by a single person, including an insider, is possible and therefore have promulgated regulations requiring the design of the safeguards systems to protect against acts of radio-logical sabotage, 10 C.F.R. 9 73.1(a).
D)
John W. Hockert, Senior Safeguards Scientist, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
IV. With respect to the guard forces at fixed sites:
(1) the present location of the plutonium for the CRBR, (2) the CRBR fuel fabrication facility and (3) the CRBR site:
Interrogatory 1 What does the Staff consider to represent the design basis threat around which the guard force must be structured?
i)
In your answer specify the number of individuals in the intruding force (both inside employees and outsiders), their training and discipline
'id the possible armament that they will employ.
ii) In your answer specify the requirements of the guard force; i.e. to repel the attack or to delay the attack for X minutes until the assistance of a reaction force arrives.
Response
A)
The design basis threat for licensed facilities is published in 10 C.F.R. 5 73.1.
The design basis threat for DOE facilities is specified in D0E's 1976 threat guidance, which is classified.
The Staff believes that safeguards programs designed in accor-
4 dance with DOE's threat guidance can be expected to provide a level of protection against theft and sabotage as high as that provided by programs designed in accordance with NRC's design basis threat.
B)
Code of Federal Regulations, Title 10 (Energy).
D)
Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Sarah A.
Mullen, Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
Interrogatory 2 What are the qualifications and the training necessary for these guards?
Would they require qualifications and training similar to that of the officers in the U.S. Marshals Service?
Response
A)
The requirements for the qualifications and training of the CRBR-site guards are contained in Appendix B to 10 C.F.R. Part 73. We have not compared these qualifications to those of the U.S. Marshal's Service. Department of Energy Order 5632.1 describes requirements for guards assigned to DOE facilities.
B) 10 C.F.R. Part 73; NUREG-0674 Security Personnel Training and Qualification Criteria; DOE order 5632.1.
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s
. 4 D)
Charles E. Gaskin, Plant Protection Analyst, Division of Safe-guards, Office of Nuclear Material Safetyn and Safeguards provided the answer to the question.
Interrogatory 3 What equipment and armaments are necessary for the guards to fulfill their mission relative to the design basis threat?
i)
Will the guards need legal authority to possess and use the required armaments?
ii) Will legislation be required to give them the authority required in (i)?
iii) Will the guards require legal authority to use the necessary force, including deadly force, in fulfilling their mission?
iv) Will legislation be required to give them the authority required in (iii)?
Response
A)
With regard to CRBR-site guards, equipment and annament normally required to be available onsite are contained in 10 C.F.R. Part 73 and Appendix B to this Part. The list includes handguns, shot-guns, semiautomatic rifles, combat helmets, gas masks, body armour and tear gas.
10 C.F.P. Part 73 explicitly sets forth the actions guards must take in the event of a threat to the facility, including the extent to which force is to be used.
No special legislation is required to provide guards with the authority to possess and use the armaments. There are no state laws which prohibit guards from exercising necessary force, including use of deadly force in self-defense, to prevent a felony when attacked by an armed adversary. Note that Sec. 235 l
l
, of the Atomic Energy Act of 1954 defines sabotage of a nuclear reactor as a federal crime.
With regard to DOE guards, general equipment requirements are contained in DOE Order 5632.1. The statements made above con-cerning guard authority would also apply to these guards.
B) 10 C.F.R. Part 73; Appendix B to 10 C.F.R. Part 73; 42 FR 64103, December 22, 1977.
D)
Charles E. Gaskin, Plant Protection Analyst, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards pro-vided the answer to the question.
I I
Interrogatory 4 How will communications and coordination with reaction forces be secured?
Response
A)
In regard to the CRBR site, 10 C.F.R. Part 73 requires that licensees establish and document response arrangements made with offsite response forces. These regulations also specify that each alarm station be equipped with both conventional telephone service, and radio-or microwave-transmitted two-way voice communications to local law enforcement authorities.
Licensees are required to develop and submit for approval a
' comprehensive safeguards contingency plan for dealing with threats, thefts and radiological sabotage.
The Applicant has not yet specified the identity, location, complement, or equipment of the forces that would provide assistance in the event of a safeguards emergency at any of the CRBR fuel cycle sites. This sort of information is not necessary for the Staff to review the overall reason-ableness of the Applicant's proposed safeguards measures for NRC's environmental review.
D)
Charles E. Gaskin, Plant Protection Analyst, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards pro-vided the answer to the question.
Interrogatory 5 What would be the required response of the guard force to a hostage situation?
Response
A)
No specific response by a guard force in t hostage situation is required by NRC regulations or suggested in Regulatory Guides.
Since the Federal Bureau of Investigation (FBI) would have juris-diction in such an event, guard forces would only be required to isolate the area pending arrival of the FBI.
Note that the
' Atomic Energy Act would prohibit the delivery of SSNM to an extortionist.
B)
Atomic Energy Act of 1954; 10 C.F.R. Part 73.
D)
Charles E. Gaskin, Plant Protection Analyst, Division of Safe-guards, Office of Ncclear Material Safety and Safeguards pro-vided the answer to the question.
V.
With respect to the guard forces associated with the transportation of plutonium or CRBR fresh fuel rods:
Interrogatory 1 What does the Staff consider to represent the design basis threat around which the guard force must be structured?
i)
In your answer specify the number of individuals (both guards and others) in the attacking force and specify the training, discipline and armaments of attacking force.
11)
In your answer specify the requirements of the, guard force; i.e., to repel the attack or to delay the attack for X minutes until the assistance of a reaction force arrives.
_ Response A)
Transportation activities in support of the CRBR fuel cycle will be performed by the Department of Energy and will not be licensed by the NRC. The design basis threat for these activities was published in DOE's 1976 threat guidance, which is classified.
The Staff believes that safeguards programs designed in accor-dance with DOE's threat guidance can be expected to provide a level of protection against theft and sabotage that is as high
4 as that provided by programs designed in accordance with the NRC's design basis threat as described in 10 C.F.R. 5 73.1.
B)
Code of Federal Regulations, Part 10 (Energy).
D)
Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Sarah A.
Mullen, Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
Interrogatory 2 What are the qualifications and the training necessary for these guards?
i)
Would they require qualifications and training similar to that of the officers in the U.S. Marshals Service?
Interrogatory 3 i
What equipment and armaments are necessary for the guards to l
fulfill their mission relative to the design basis threat?
i)
Will the guards need legal authority to possess and use the required armaments?
i ii) Will legislation be required to give them the authority required in (i)?
iii) Will the guards require legal authority to use the necessary force, including deadly force, in fulfilling their mission?
iv) will legislation be required to give them the authority required in (iii)?
v)
Will legislation be required to allow the guards to carry their armaments across state lines?
a 9 Interrogatory 5 How will communications and coordination with reaction forces be secured?
Interrogatory 6 What would be the required response of the guard force to a hostage situation?
Response to Interrogatories #2, #3, #5 and #6 A) 2.
Requirements for DOE guards are contained in DOE Order 5632. The Staff has not compared these requirements to those required for officers in the U.S. Marshal's Service.
3.
Requirements for DOE guards are contained in ODE ORDER 5632.
See the Staff response to Interrogatory IV-3 of l'
this set.
5.
The Applicant has not described the details of the reaction forces that would provide assistance in the event of a safeguards emergency during the transport of CRBR-related materials. This sort of information is not necessary for the Staff to review the overall reasonableness of the Applicant's proposed safeguards measures for NRC's envi-ronmental review.
6.
See the Staff response to Interrogatory IV-5 of this set.
B)
DOE Order 5632.
r D)
Carl B. Sawyer, Senior Program Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the questions.
VI. With respect to reaction forces (i.e. emergency forces that would respond with assistance in the case of an attack on a fixed site or a transport element):
Interrogatory 1 What does the Staff consider to represent the design basis threat around which the reactor force must be structured?
i)
In your answer specify the number of individuals in the attacking force and specify their training discipline and armaments.
ii)
In your answer specify the mission of the reaction force; i.e.
to repulse and apprehend the attackers or failing that to recover the stolen plutonium.
Interrogatory 2 What are the requirements relative to size, specialties (table of organization) and disposition of these reaction forces?
Interrogatory 3 What are the qualifications and training necessary for the members of these forces?
i)
In your response be specific with respect to each specialty in the table of organization.
Interrogatory 4 What equipment and armaments are necessary for the reaction forces to fulfill their mission relative to the design basis threat?
j i)
Will the forces need legal authority to possess and use the required armaments?
- 11) Will legislation be required to give them the authority required in (i)?
(
' iii) Will the forces require legal authority to use the necessary force, including deadly force, in fulfilling their mission?
iv) Will legislation be required to give them the authority required in (iii)?
v)
Will legislation be required to allow the guards to carry their armaments across state lines?
Interrogatory 5 How will communications and coordination with and between reaction forces be secured?
Interrogatory 6 What would be the required response of the reaction forces to a hostage situation?
Response to Interrogatories #1 through #6 A)
During the environmental review the Staff does not conduct a review of the relationship between the reaction forces and the sites. The Staff, therefore, does not have the requested information.
D)
R. Davis Hurt, MC&A Program Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
VII.
In the event of a successful theft of plutonium, does the Staff anticipate any of the following events might occur during recovery operations and if not, why not?
Interrogatory 6 Atomic bomb explosion?
i
, Response A)
The Staff does not anticipate that an atomic bomb explosion would occur during recovery operations. Such a hypothetical device could be a total failure, because of either faulty design or faulty construction. A great deal depends upon the competence of the group; if it is deficient, not only is the chance of producing a total failure increased, but the chance that a member of the group might suffer serious or fatal injury would be quite real.
B)
Nuclear Proliferation and Safeguards, Congress of the United States Office of Technology Assessment, 1977.
D)
John N. Hockert, Senior Staff Scientist, Division of Safeguards, Office of Nuclear Material Safety and Safeguards Paul Baker, Research and Technical Assistant Program Manager, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
VIII. With respect to the employees, including guards, at all CRBR related facilities and those associated with transporation, does the Staff consider it necessary that these employees undergo security clearances?
Interrogatory 1 If not, why not?
Interrogatory 2
- 1) yes, what level of clearance (i.e. Q)?
If Explain the basis for the answer.
Response to Interrogatories #1 and #2 A)
In regard to the guards and other employees at the CRBR site, 10 C.F.R. Part 11 requires that all individuals granted unescorted access have a NRC Special Nuclear Material Access Authorization. All members of the security force, certain members of management, and all individuals granted unescorted access to special nuclear material or vital areas would require clearances based on full field background investigations (equivalenttoanNRC"Q").
Individuals granted unescorted access only to the protected area would require clearances based on a National Agency Check (equivalent to an NRC "L").
Similar requirements are contained in DOE Order 5632.2 for individuals having access to SNM at DOE facilities.
In both cases, the authority for trustworthiness determinations is contained in Section 161, i, (2) of the Atomic Energy Act which directs that "to guard against loss or diversion of any special nucicar material" activities involving certain quanti-ties of special nuclear material may only be conducted by persons whose character, associations and loyalty have been investigated.
L
. B) 10 C.F.R. Part 11; DOE Order 532.2; Atomic Energy Act of 1954.
)
D)
Charles E. Gaskin, Plant Protection Analyst, Division of Safe-l 1
guards, Office of Nuclear fiaterial Safety and Safeguards pro-l vided the answer to the question.
IX. With respect to the employees, including guards, at all CRBR related facilities and those associated with transporation, does the Staff consider it necessary that these employees undergo psychological profile tests?
Interrogatory 1 4
If not, why not?
t Interrogatory 2 If yes, what particular test (s) would you consider necessary?
i)
Explain the basis for your answer.
Response to Interrogatories #1 and #2 4
A)
Psychological profile tests are not currently required by NRC regulations. The issue of psychological tests for licensed power reactor employees is currently under study by the Staff.
1
]
D)
Tom R. Allen, Section Leader, Regulatory Activities Section, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
1 X.
Does the Staff consider that intelligence information gathering is an essential part of an adequate safeguards system?
Interrogatory 1 If not, why not?
._ =
4 Interrogatory 2 If yes, who or what organization would coordinate the collection and use of this information?
i)
Would this be the same organization that coordinates the actions of the fixed site guards and reaction forces?
Response to Interrogatories #1 and #2 A)
The utilization of intelligence information is only incidental to the performance capability of the NRC Safeguards system.
NRC will use whatever intelligence information is supplied by law enforcement authorities to alert nuclear facilities to possible attack.
D)
Harvey B. Jones, Jr., Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards and Sarah A.
Mullen, Safeguards Analyst, Division of Safeguards, Office of Nuclear Material Safety and Safeguards provided the answer to the question.
l
N 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
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PROJECT MANAGEMENT CORPORATION
)
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 Interrogatories #1 through #4 of Section I of the 8th Set 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, 198 E Notary Public 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 ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards.
2.
I am duly authorized to participate in answering Interrogatories in Section IV, #1 through #5;Section V, di through #6;Section VI,
- 1 through #6;Section VII, #1 through #6;Section VIII, #1 and #2;Section IX, #1 and #2; and Section X, #1 and #2 of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge.
ROBERT J. DUBE Subscribed and sworn to before me th'_
day of April, 1982.
Notary Public My Comission expires:
k 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 JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:
i r
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 Interrogatories #1 through #7 in Section II of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge.
Jerry J. Swif t Subscribed and sworn to before me this day of April, 1982.
. Notary Public My Commission expires:
..