ML20052C488
| ML20052C488 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/30/1982 |
| From: | Dalinsky B, Penico E, Stewart J JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205050040 | |
| Download: ML20052C488 (60) | |
Text
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UNITED STATES OF AMERICA // vackersa fgg. %Nn: b NUCLEAR REGULATORY COMMISSION - _
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) b In the Matter of a UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION )
TENNESSEE VALLEY AUTHORITY ) Docket No. 50-537
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(Clinch River Breeder Reactor ) g' s Plant) ) g, 5/
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APPLICANTS'UPDATEDRESPONSETO]l, v.. d NATURAL RESOURCES DEFENSE /'
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COUNCIL, INC. AND THE SIERRA CLUB EIGHTH SET OF
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.J je INTERROGATORIES TO APPLICANTS o :x ' AJ '
Pursuant to 10 CFR S 2.740b, and in accordance
- y' Q'dlly, with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy, Project Management Corporation, and the Tennessee Valley Authority (the Applicants) hereby file their updated responses to the Natural Resources Defense Council, Inc. and the Sierra Club Eighth Set of Interrogatories to the Applicants, dated May 7, 1976. /
- / Applicants previously responded to these interroga- gS63 tories on June 11, 1976. Applicants have prepared s these updated responses to establish a current base of information for the CRBRP for the purpose of expediting these proceedings. Accordingly, in providing these I[
responses, Applicants do not concede that the infor-mation contained therein is admissible in or necessary to a decision in the LWA proceeding. Applicants have Continued B205050040 820430 PDR ADOCK 05000537 C PDR
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2-Answers to General Questions (a) - (f)
(a) Provide the direct answer to the question.
ANSWER: See the direct answers below under heading " ANSWER."
(b) Identify all documents and studies, and the particular parts thereof, relied upon by Applicants, now or in the past, which serve as the basis for the answer. In lieu thereof, at Applicants' option, a copy ref such document and study may be attached to the answer.
ANSWER: See the direct answers below under heading " DOCUMENTS."
(c) Identify principal documents and studies, and the partreular parts thereof, specifically examined but not cited in (b) . In lieu thereof, at Applicants' option, a copy of each such document and study may be attached to the answer.
not furnished copies of or made available for inspec-tion and copying those documents referenced in this response which were previously referenced and made available pursuant tc the Applicants' previous responses. Documents referenced for the first time in this update response will be made available upon request. General questions and responses follow the protocol agreed upon by the parties and attached to Mr.
Greenberg's March 8,1982 Letter to Counsel for PMC.
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ANSWER: ' Unless otherwise indicated below in regard to the answer under the heading
" DOCUMENTS;" none.
(d) Identify by name, title and affiliation the primary Applicant employee (s) or
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. consultant (s) who provided the answer to the question.
ANSWER: See the attached ~ affidavits.
- (e) Explain whether Applicants are presently engaged in-or intend to engage in any further, ongoing research program which may affect Applicants' answer. This answer need
.be provided only in cases where Applicants intend to rely upon ongoing research not
, included in F'.e;'.ar, ~1.5 of the PSAR at the LWA or can r 'r ton permit hearing on the
. . _ _ CRBR~. Failure to prdhide such an answer means that Applicants do not intend to rely upon the existence of any such research at the LWA or construction permit inaring on the CRBR.
If not in Section 1.5 of the PSAR and ANSWER:
the direct answer below; none.
(f) Identify the expert (s), if any, which
, Applicants intend to have testify on the
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l subject matter questioned, and state the qualifications of each such expert. This i answer may be provided for each separate question or for a group of related '
questions. This answer need not be provided until Applicants have in fact identified the expert (s) in question or determined that no ;
expert will testify, as long as such answer provides reasonable notice to Intervenors.
ANSWER: Applicants have not yet identified the expert (s) in question.
L Interrogatory.
I. Nucleonics Week (April 22,1976, p.2) states:
After more than a year of review and debate, ERDA has decided to take over all shipments of its own so-carled ' strategic special nuclear materials,' a l category comprising plutonium and highly enriched uranium [by October 1, 1976].
- 1. Is this statement true? If not, explain fully the basis for your answer.
- 2. Would this action cover shipments of CRBR fuel?
- 3. Would these ERDA shipments, particularly the CRBR shipments, be under NRC license, or under an NRC approved safeguards plan?
f
- 4. Identify and supply all ERDA safeguards regulations ;
governing ERDA shipments of strategic special nuclear I
materials.
- 5. Explain fully and precisely how ERDA safeguards ,
regulations governing shipment of strategic special nuclear materials differ from NRC safeguards regulations.
- 6. Identify and supply all documents, reports, internal .
memoranda, etc., that ERDA considered in its decision to j take over all shipments of its own strategic special nuclear material. l
- 7. Identify those documents, reports, internal memoranda, !
etc., identified in 6 above that ERDA believes justifies its ;
l decision. l
- 8. Does ERDA believe that the NRC safeguards regulations [
governing shipment of strategic special nuclear materials or -;
the implementation of these safeguards by licensees (i.e.,
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shipment of ERDA's own materialr3) are adequate? If not, why ,
i not? ;
Answer.
t l I. Nucleonics Week (April 22, 1976, P.2) states:
"After more than a year of review and debate, ERDA ,
i haa decided to take over all shipments of its own so-called r
' strategic special nuclear material,' a category comprising.
plutonium and highly enriched uranium" [by October 1,1976] .
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- 1. The above statement is not completely !
accurate. As a result of objections by private business interests, a review of the 1974 decision of the AEC (now DOE) to expand its weapons transportation system to include movement of strategic quantities of Government-owned special nuclear materials (SNM) was conducted early in 1976. As a result of the review, the decision was affirmed by the Administrator of ERDA. The strategic quantities of SNM referred to include quantities equal to or in excess of 2 kg of plutonium, 2 kg of uranium-233, or 5 kg of uranium enriched to 20% or more uranium-233. ;
- 2. Yes.
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- 3. These shipments, including the CRBR shipments, '
will be made in accordance with a DOE-approved safeguards plan. ,
- 4. The current regulations, DOE Order 5632.2,
" Physical Protection of Special Nuclear Materials," will be made available for inspection and copying.
- 5. Corresponding NRC regulations are contained in l
10 CFR 73. With respect to similarities and differences the 1
regulations speak for themselves.
- 6. The original decision, as stated in our reply :
to Item I.1, was made by the former Atomic Energy Commission, and that decision was later affirmed by the ,
- Administrator, ERDA, following the establishment of ERDA.
The documents tnet were used in the decision process were:
AEC SECY-R-74-216, May 22, 1974,
SUBJECT:
ADDITIONAL REQUIREMENTS FOR THE PROTECTION OF STRATEGIC NUCLEAR MATERIALS AND OVERALL PROGRAM PLAN FOR THE PROTECTION OF PLANTS AND MATERIALS IN THE LICENSEE SECTOR. (Official Use Only)
AEC SECY-75-46, July 12, 1974,
SUBJECT:
TRANSPORTATION OF AEC-0WNED SPECIAL NUCLEAR MATERIAL (SNM). (Classified)
ERDA Action Memorandum to the Administrator, ERDA, from Alfred D. Starbird, Assistant Administrator for National Security,
SUBJECT:
TRANSPORTATION OF STRATEGIC QUANTITIES OF GOVERNMENT-0WNED SPECIAL NUCLEAR MATERIALS (SNM), March 29, 1976.
(With classified enclosures.)
- 7. See 6, above.
- 8. DOE believes that it is not in a position to comment on the adequacy of the regulations of another Federal agency.
Interrogatory.
II. I. Since the Applicant has indicated that there are no significant quantities of separated domestic power reactor
plutonium and it is not aware of the availability of foreign Pu for the FFTF and CRBR fueling, are we correct in assuming that Pu to be used in the CRBR will come from the DOE stockpiles?
Answer.
11.1. As a result of the Evard's April 6,1982 ruling and April 14,1982 Order in regard to NRDC's Contention 17, the answer is not necessary.
Interrogatory.
II. 2. What are the relative concentrations of the plutonium isotopes in:
a) Fresh CRBR fuel in the core obtained from ERDA?
I b) Fresh CRBR fuel obtained from reprocessed LWR fuel?
c) Spent CRBR fuel removed from the reactor core area?
d) Spent CRBR fuel removed from the axial blanket area?
Answer.
II. 2. a) Initial CRBR loadings are provided in PSAR I 4.2-4.
b) Typical loading of CRBR fuel obtained from reprocessed LWR fuel will be as follows:
_9-Pu-238 0.9 wt.%
Pu-239 65.6 wt.%
Pu-240 21.8 wt.%
Pu-241 9.0 wt.%
Pu-242 2.7 wt.%
Documents.
BNWL - 2086, L. G. Faust, et al., "A Guide to Good Practices at Plutonium Facilities",. dated July 1977, Chapter 1. !
(c) Typical concentrations of CRBR fuel removed from the reactor core are provided in PSAR Table 4.3-4. ,
d) Typical concentrations of spent CRBR fuel removed from the axial blanket are provided in PSAR Table 4.3-4.
Inte rrogato ry .
11.3. Will the Pu from ERDA inventories, because of its isotopic composition, represent a preferred material for the construction of atomic bombs as opposed to material that would be extracted from high burnup reactor fuel? t i
Response
11.3. Yes. It is preferable to high burnup reactor fuel, to the extent that the Pu composition alone is cons id e red . However, it is not necessarily preferable to low burnup reactor fuel. Preferred material for " atomic
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10 - i bombs" is a complex issue that cannot be addressed simply by i examining the chemical and isotopic compositions of the various classes of reactor fuels cited. Other factors in such a definition would include, but not be limited to, material form or availability, radiological hazards posed in production operations, and time, equipment, knowledge, and resources required between acquisition of the fuel and its processing.
Interrogatory.
III. In answer to Interrogatory 18(a) (1st Set) the Applicant indicated ERDA available plutonium inventory as of ,.
June 30, 1975, suitable for use in CRBR, FFTF and ZPR programs was 5700 kg. The N reactor produces Pu at the rate of about 600 kg per year. In answer to Interrogatory 16(a) the Applicant indicated the ZPR requirements were about 2300 i
Kg and the FFTF requires 750 kg per year. In answer to Interrogatory 11 the Applicant stated with equilibrium loading the CRBR core contains 1700 kg of plutonium metal and the total lifetime requirement of the plant could be as high as 20,000 kg or as low as 2900 kg (assuming idealized recycle). Based on these data it appears that there is insufficient plutonium to fuel the CRBR over its lifetime.
- 1. Please provide a complete and detailed analysis demonstrating that there is sufficient plutonium to supply the fuel for the CRBR, ,
t l
l including in the analysis the following
(
l information as a function of time (e.g., by year):
a) Pu inventory (stockpile available).
b) Pu utilization in ZPR.
c) Pu utilization in CRBR.
d) Pu utilization in FFTF.
Answer.
111.1. As a result of the Board's April 6,1982 ruling and April 14,1982 order in regard to NRDC's Contention 17, the answer is not necessary.
Interrogatory.
III. 2. Where are the ERDA inventories located? Identify the amounts at each location.
Answer.
III. 2. As a result of the Board's April 6,1982 ruling and April 14, 1982 Order in regard to NRDC's Contention 17, the answer is not necessary.
Interrogatory.
III. 3. Are there other ERDA inventories of Pu that are not presently aviailable for the LMFBR program? If considera-tion is being given to releasing these at some future time for use in the LMFBR program, discuss the quantities availa-ble, the isotopic concentration, and the locations of these materials.
Answer.
III. 3. As a result of the Board's April 6,1982 ruling and April 14,1982 Order in regard to NRDC's Contention 17, the answer is not necessary.
Interrogatory.
111.4. Assuming no new licenses are issued for commercial processing of plutonium fuel, where might the plutonium be shipped for fabrication into fuel rods?
Answer.
111.4. The plutonium feedstock for fuel fabrication will be shipped to the Hanford Reservation in Richland, Washington.
Inte rrogato ry .
III. 5. Discuss the method of shipment, the possible and probably shipping routes, and shipping distances are involved with respect to shipments:
a) from the ERDA stockpile to the fabricating plant; b) from the fabricating plant to the CRBR.
Answer.
III. 5. a) Method of shipping would be by highway. The CRBRP core fuel is planned to be fabricated at the Secure Automated Fabrication Facility being built on the Hanford Res e rvation, Richland, Washington. The location from which
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i the plutonium for CRBRP fuel will be obtained has not yet ;
been determined. The Applicants are, therefore, unable to identify shipping routes and distances from the source of plutonium to the fabricating plant.
b) Information is provided in ER Section 3.8.2 and 5.7.1.
i i Interrogato ry .
IV. With respect to the initiation of accidents at the CRBR:
- 1. Would it be possible for one insider, acting alone, to initiate a TOP accident without scram, i at the CRBR? Explain in detail the basis for the answer. '
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- 2. Would it be possible for two insiders, acting in collusion, to initiate a TOP accident without screw, at the CRBR? Explain in detail the basis for the answer.
- 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.
- 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.
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Answer.
I IV. It is highly improbable that a transient overpower or loss of flow accident without scram could be initiated. Multiple layers of controls and safeguards are i i
available within the security system, plant protection j 4 i system and control system to preclude such an event. !
e Personnel with access to vital equipment must undergo security clearances. Access by unauthorized personnel is restricted by use of card readers, watch standards, and locked and alarmed doors. In addition, detailed knowledge of the design and operation of the plant protection system, control system and hardware would be required. Furthermore, ;
the plant is equipped with alarms which would foreclose any i
i attempt to place the plant in an unsafe condition. ;
Among the multiple layers of controls and safe- ;
guards which have been incorporated in the plant design, and !
which would preclude the circumstances raised by the question are: !
- 1. The primary plant protection system logic train panels are separated and locked. Entrance to each !
panel is further protected by alarms which enunciate to the l operator. Efforts to short-circuit the logic trains could i result in indications of an abnormal condition to the f I operator.
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- 2. The secondary plant protection system logic train panels are separated and locked. Entrance to panels is further protected by alarms which enunciate to the operator. Efforts to defeat the logic trains could provide indications of an abnormal condition to the operator.
- 3. The manual control system is designed with widely separated manual scram buttons. At least one reactor operator will be stationed at the control board at all times so that there will be assurance that unauthorized personnel do not have access to the manual control system.
Thus, the combination of administrative and system control and safeguards available within the security system and plant protection provide multiple layers of protection to provide assurance that the reactor will not be placed in a condition from which the TOP or LOF events without scram could be initiated.
The plant design contains additional features which would preclude the specific transient overpower and loss of flow events. In the caso of transient overpower, entrance must be gained to separate PPS equipment or the control system which are locked, alarmed and enunciate to the operator. In the case of loss of flow, access through separated locked panels and alarms would be required to override control signals.
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The modifications needed to be made would depend )
on the operating condition of the reactor, further compli-cating the task and reducing the probability of successful completion. Even assuming the highly improbable initiation of a transient, depending on the configuration of the l l
control system, the action taken to initiate the transient l might only be partially effective and not lead to a signi-ficant core transient.
In order for the implied actions of the descrip-tion above to be carried out successfully, many precise manipulations of electronic / electrical circuitry must be performed and have little margin for error. Any mistake could result in a reactor trip. In addition, upon indica-tion of abnormal conditions or alarms, the reactor could be scrammed from a number of remote locations and maintained in a safe shutdown condition.
The conclusion that successful completion of the scenario is highly improbable is not sensitive or dependent upon whether one or two insiders are postulated to be involved. This is based upon the fact that all personnel that will be employed at the CRBRP will undergo a security clearance as indicated in response to question IX in this set of interrogatories.
o , .
Interrogatories V through XIII Preamble to Answer to Interrogatories V through XIII In order to provide a suitable framework for understanding the Applicants' position on the issues raised by these interrogatories, the following facts on the Appli-cants ' safeguards policies are provided.
The general objective of the nation's safeguards I
program, which is being supported by the Applicants, is to prevent successful malevolent acts involving nuclear mate-rials and facilities. This objective can be met through an in-depth approach that looks to: (1) deterring attempts, (2) minimizing possibilities of success, and (3) minimizing consequences.
To achieve this objective, the Applicants use a system composed of three basic elements: physical protec-tion, material control, and accountability. The general composition of each of these elements as it relates to the ,
overall system objective, is as follows:
(1) physical protection comprises measures related to access controls, physical barriers, penetration alarms, and armed protective response and recovery forces; (2) material control procedures are those measures in effect where special nuclear materials are being handled and processed which provide constant and ready "
l surveillance of the materials themselves; and l
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(3) accountability systems are comprised of those systems which involve bookkeeping data on the location of special nuclear material inventories and those pro-cedures used to verify through measurements, the physical inventory of special nuclear material as compared with the bookkeeping records.
A fourth element, personnel security clearances, is employed by the Applicants to assure that people with access to special nuclear materials or classified informa-tion pertaining to special nuclear materials will not pose an internal threat. The clearance program acts as a resource to the three elements of the overall safeguards system in providing assurance that those responsible for handling and/or guarding nuclear materials will perform reliably.
In their systems role, and in addition to their prevention and deterrence functions, physical protection procedures and measures provide for immediate detection of SNM misappropriation along with a redundant capability for
., such immediate detection in the material control proce-dures. Accountability systems provide primarily for a final evidence that the other two systems have achieved their purpose and, in the event they have not, the accountability systems provide data to facilitate tracking events and isolating the location where the other systems failed.
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Additionally, such data could be of considerable value in connection with recovery objectives.
With regard to the threat against which the safe-guards system must protect, the concept of a " design basis threat "needs to be placed in context. To the highest degree possible, the Applicants' approach with the three elements cited above is to make the protection of facilities and special nuclear material threat-independent. It should also be recognized that definition of what may be treated as a nominal or credible threat is a continuing process which must take account of changing societal situations and advances in technology. For example, in December, 1973, then-Chairman (of the AEC) Dixy Lee Ray cited "a theoretical standard involving an attack by 10 terrorists armed with light weapons" (letter to Rep. Melvin Price dated 7 December 1973) .
As a result of continuing studies on threat characterization by the Applicant, the 10 cited by Chairman Ray may now be more appropriately described as a range of threats including a group of well trained outsiders armed with automatic weapons and assisted by a single insider.
The essential point is that the understanding of threat is evolving as a result of the Applicants' intensive research into the motivations and capabilities of personnel and
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groups who could pose threats to nuclear plants and special nuclear materials.
Perhaps the single most important conclusion that has been reached to date as a result of that research is that the safeguards system must respond to a spectrum of threats. Response to a given threat will be oriented towards meeting the overall safeguards objectives; i.e., the Applicants' safeguards systems are performance oriented to the greatest extent practicable. (A more formalized discus-sion of how safeguards may be assessed as to their ability to counter threats may be found in a paper published in June, 1975, by ERDA: ERDA-7, " Societal Risk Approach to Safeguards Design and Evaluation.")
Because threat definition is a continuing process which must take account of changing societal situations and advances in technology, it is not useful to identify a point in time at which threat definition for CRBRP and its related facilities (as part of the overall LMFBR Program) can be terminated. A description of the present status of threat studies is given in Section VI.2.2, DOE /EIS-0085-D, December , 1981.
In responses to the Interrogatories that follow, it must be kept in mind that the CRBR will be subject to NRC license and inspection requirements. The probable location of the fuel fabrication facility for CRBR is at Hanford
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l (Richland, Washington) which, as a DOE facility, is exempt from licensing. In general, while the regulatory responsi-bilities of NRC and the developmental responsibilities of the Applicant (DOE) must be clearly separated, the activi-ties of the two agencies toward improved safeguards will be coordinated. It is the Applicants' policy that there be parity between safeguards in the private sector and the government sector. To secure parity, DOE, in accordance with the provisions of the Energy Reorganization Act of 1974 (PL 93-438) and the Department of Energy Organization Act !
(PL 95-91), consults and coordinates with NRC planning related to threats, theft and sabotage of special nuclear {
material (PL 93-438, Section 204) .
Specifically, DOE Order 5632.2, paragraph 5 states: " Policy and Objectives: It is the DOE policy to ;
physically protect all special nuclear material against theft. This order is designed to facilitate effective safeguards and security systems through graded, performance-evaluated physical protection requirements for special nuclear material. The minimum standards have been so ,
designed as to satisfy the policy requirements that the effectiveness of nuclear safeguards and security systems in DOE activities provide comparable effectiveness with that required of licensees by the Nuclear Regulatory Commission."
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- i Thus will the Applicants comply not just with the ;
letter of license conditions, but also with their spirit, since the Applicants will be party to evolution of those requirements. In particular, the Applicants will make their experience in safeguards system design and operating experi- ,
ence available to the industry and to NRC.
The safeguards R&D at the CRBRP follow the general approach of DOE's work at Sandia Laboratories. The work at Sandia Laboratories specifically on the CRBRP is of a con-firmatory nature such that the system, as the Project Office has preliminarily designed, has enough features to provide delay until the on-site guards, or the off-site law enforce-ment assistance, can neutralize the threat. The decision on the degree of applicability of the results of the programs to the CRBRP will be based on the CRBRP Principal Project Objectives, NRC licensing requirements, and overall DOE policy.
The following activities that are being performed are:
(1 ) Vulnerability Analysis will identify combinations of events which, if initiated, could result in theft or sabotage. -
(2) Location Analysis will identify the physical locations where these events mentioned above could be initiated.
l (3) Critical Path Analysis will identify paths for adver-sary attack that offer the highest probability of adversary success.
(4) Dynamic Simulation Models will evaluate the relative effectiveness of the technological safeguards system coupled with on- and off-site response capabilities in defeating adversary attacks.
Documents upon which Applicants rely for this answer include:
(1) DOE Order 5632.2; (2) DOE /EIS-0085-D, December, 1981.
Interrogatory V. With respect to the guard forces at fixed sites:
a) the present location of the plutonium for the CRBR; b) the CRBR fuel fabrication facility; and c) the CRBR site; l
- 1. What does the Applicant 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 and 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 t to delay the attack for X minutes until the assistance of a reaction force arrives.
Answer V. 1. Refer to the Preamble for a general discussion of the " design basis threat." For the CRBRP site, the guard force is structured around the design basis threat given in 10 CFR Part 73. DOE facilities are required to be comparably effective.
Interrogatory.
- 2. What are the qualifications and the training -
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necessary for these guards?
(i) Would they require qualifications and
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training similar to that of officers in the U.S.
Marshals Service?
Answer.
- 2. To the extent that facility / site guards' training and qualifications are specified by the Applicant (DOE) and not by NRC license qualification or regulation, an appropriately updated DOE IMD 6102, Part IV would apply. This reference will be made available for l inspection and copying. In general, the qualifications necessary for DOE federal guards or contractor guards l
protecting DOE facilities possessing significant quantities of plutonium include compliance with: (1) medical standards and (2) mental qualifications.
Training prior to assignment to duty involves formal indoctrination, and completion of a prescribed course. Written examinations or an appraisal are required to verify the guard's readiness to complete the responsibilities assigned to him. Annual refresher courses are conducted.
Guards would require qualifications and training dissimilar to personnel in the U.S. Marshal's service in view of the dissimilarity of functions performed by DOE guards and U.S. marshals.
For the CRBRP plant site, the Applicants intend to comply with the NRC regulations and Reg. Guides as indicated in Section 13.7 of the PSAR.
At the CRBRP plant site, the TVA public safety officers will meet the requirements of all applicable NRC l regulations pertaining to the training and qualification of guards. In meeting these regulations for training and qualification, TVA will be guided by the provisions of NRC Regulatory Guide 5.20 (January 4, 1975) which provides criteria acceptable to the Regulatory staff for a program of training, equipping and qualifying guards and watchmen.
1 In t erro gatory,.
- 3. What equipment and armaments are necessary for the guards to fulfill their mission relative to the design bar'. *hreat?
(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 autho-rity 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) ?
Answer.
- 3. Refer to the Preamble for a general discussion of the " design basis threat." To the extent that guards' ,
equipment and armament are specified by the Applicant (DOE) and not by NRC regulation, the following gene- !
rally applies at this time (refer to DOE IMD 6102, Part IV for additional detail):
DOE guard forces must be distinctively uniformed while on duty and identified with their function by appro-priate emblems or badges.
DOE guard forces are required to be armed while on duty with revolvers of not less than .38 caliber. Addi-tional weapons, such as rifles, riot guns, shotguns, and tear gas grenades, are required to be avellable for, and issued to, guard forces as necessary. f With respect to the legal aspects of V.iii, there is adequate authority existing under federal statutes L
(particularly Section 161.k of the Atomic Energy Act of 1954, as amended) for DOE federal and contractor guards to possess the required armaments at facilities owned by or l
contracted to the United States. DOE IMD 6102, Part IV, ;
sets forth the general policy of DOE on use of force, including deadly force, by DOE federal and contractor guards. The matter of use of force by such guards is under ,
continuing study.
The authority of non-DOE federal and private guards (other than DOE contractor guards) to possess and use armaments will be specified by NRC regulations and license conditions.
l Interrogatory.
- 4. How will communications and coordination with reaction forces be secured?
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Answer.
- 4. The Applicants will provide for timely and effec-tive communications and coordination in response to a real or threatened nuclear emergency, including violent attacks whose goal is malevolent end use of SNM, whether at fixed sites or in transit. To assure immediate response Applicant maintains close contact with federal and local law enforcement agencies.
Gathering resources for DOE support is accomplished by the Emergency Action and Coordinating Team (EACT),
which assembles the appropriate expertise needed for a given situation.
Interrogatory.
- 5. What would be the required response of the guard force to a hostage situation?
Answer.
- 5. The required response of the guard force to a hostage situation now involves coordination with FBI and local law enforcement authorities and utilization of their expertise and capabilities in dealing with such situations. l l
l Interrogatory.
VI. With respect to the guard forces associated with the transportation of plutonium or CRBR fresh fuel rods:
- 1. What does the Applicant 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.
(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 assis-tance of a reaction force arrives.
Answer.
- 1. Refer to Answer to V.1.
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. Marshal's service?
l Answer.
- 2. The Applicant (DOE) employs couriers rather ;han guards to provide armed protection for strategic quantities of special nuclear materials (including l plutonium) in transit. DOE Order 5632.1, " Physical l
, - , , -n. .,
. Protection of Classified Matter," provides general standards for courier qualifications and training. The Albuquerque Operations Office, charged with operational responsibility for the transportation of strategic quantities of SNM, amplifies on courier training and qualifications in AL Chapter 24XA, "The DOE Transpor-tation Safeguards System." DOE couriers undergo a specialized training course of eight weeks which includes training in the use of automatic firearms, the handling of nuclear incidents, safety considerations in the handling of nuclear and high explosive (chemical) materials and mission procedures. Periodic refresher courses in the above are required and couriers must ,
qualify four times a year with the firearms they carry.
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 l them the authority required in (i)?
(iii) Will the guards require legal authority to use the necessary force, including i
deadly force in fulfilling their mission?
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. (iv) Will legislation be required to give them authority required in (ii)?
(v) Will legislation be required to allow the guards to carry their armaments across state lines?
Answer.
- 3. There is adequate authority under federal statutes particularly 161.k of the Atomic Energy Act of 1954, as amended, for DOE federal guards to possess the required armaments and to carry these armaments across state lines. DOE Order 5632.1A, " Physical Protection of Classified Matter," sets forth the general policy of DOE on the use of force, including deadly force, by DOE federal guards. The matter of use of force is under continuing study by DOE.
Interrogatory.
- 4. How will communications and coordination with reaction forces be secured?
Answer.
- 4. DOE shipment vehicles are equipped with a nation-wide communications system which permits instantaneous and constant contact with a central command post from which reaction forces would be dispatched.
Interrogatory.
- 5. What would be the required response of the guard force to a hostage situation?
Answer.
- 5. Refer to answer to V.(5).
Interrogatory.
VII. 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):
- 1. What does the Applicant consider to represent the design basis threat around which the reactor force must be structured?
(i) In your answer, specify the number 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).
- 2. What are the requirements relative to size, specialities (table of organization) and disposition of these reaction forces?
. o .
- 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.
- 4. What equipment and armaments are necessary for the reaction forces to fulfill their mission relative to the design basis threat?
(i) Will the forces need legal autho-rity to possess and use the required armaments?
(ii) Will legislation be required to give them 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?
)
- 5. How will communication and coordination with and between reaction forces be secured?
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. 6. What would be the required response of the reaction forces to a hostage situation?
Answer.
VII. This presumably refers to prompt response forces which may be other than DOE federal or contractor guards such as local law enforcement agencies (LLEA) and FBI except in a hostage situation.
- 1. (i) Refer to answer to V.1 (ii). Mission is to neutralize and apprehend attackers.
- 3. DOE does not specify.
- 4. DOE does not specify armaments. LLEA have legal authority for weapons, to use force. The NRC Security Agency Study was issued as: " Report to the Congress on the Need for, and the feasibility of Establishing a Security Agency within the Office of Nuclear Material Safety and Safeguards."
NUREG-0015, Aug. 1976.
- 5. Refer to answer to V.4.
- 6. Refer to answer to V.4.
In Applicants' Response to the 16th Set of Inter-rogatories, Contention 5, Question 1, section f, it was l
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- noted that an answer would be provided concurrent with the updating of answers to the 8th set,Section VII.
Question 1.f. of NRDC 's 16th Set of Interroga-tories is worded as follows:
- f. To the extent not provided in updating answers to Intervenors' Eighth Set of Interrogatories,Section VII, define the response time applicants deem to be adequate for detecting the diversion of an amount of such material considered to be of safeguards significance.
Response
Section VII of the Eighth Set of Interrogatories pertains to response forces. The responses to this set of ,
interrogatories have been updated. None of the questions in Section VII specifically request definition of the response time that Applicants might deem adequate for detecting the diversion of an amount of material of safeguards signifi-cance. As is explained in WASH-1535 (VI Section 7.4), ERDA-1535 (III-C) and the Supplement to ERDA1535 dated Dec. 1982 (pp. 145-172), however, the objective of the DOE safeguards i and security program is to prevent the theft or diversion of any safeguards significant amount of nuclear material. By combinations of containment, surveillance, material controls, barriers, and searches of personnel and containers leaving
material access areas, diversion attempts should be detected in time to interrupt them.
Interrogatory.
VIII. In the event of a successful theft of plutonium, does the Applicant anticipcte any of the following events might occur during recovery operations and if not, why not?
Answer.
VIII. 1. Search without warrant - We anticipate appro-priate search warrants will be obtained in all cases where it is possible to do so and accomplish recovery objectives.
- 2. Area search - Applicants are unclear of the Intervenor's definition " area search." In general, DOE maintains on standby alert the Nuclear Emergency Search Team (NEST), which deploys sophisticated material detection devices (portable surface and airborne) to aid in the detec-tion and recovery of potentially stolen special nuclear material.
- 3. Detention and interrogation without warrant -
We anticipate that a person (s) lawfully arrested may be detained and questioned for a brief period of time befoce being turned over to local law enforcement officers.
- 4. Martial law would not be anticipated solely on the basis of a successful theft of plutonium and the attempt to recover the item. Martial law is normally applicable l
. where civil authority has broken down and the military is required to prevent disorder. This would not be applicable.
- 5. Atomic bomb blackmail threat - portions of the Applicants' R&D on threat definition and characterization will include methods to assess the credibility of a given blackmail threat. Whether or not there will be such black-mail cannot be realistically assessed at this time. Past experience has shown that mentally imbalanced individuals (as opposed to groups) have and probably will continue to make irrational, unfounded threats of nuclear explosions which can be quickly verified as non-credible.
- 6. Atomic bomb explosion - This is considered extremely unlikely in view of the that Applicants' safe-guards are and will continue to be designed around provision of the highest degree of assurance thataSNM of form and quantity suitable for fabrication of a nuclear explosive device will be secured against diversion.
Interrogatory.
( IX. With respect to the employees, including guards, at all CRBR related facilities and those associated with transpor-tation, does the Applicant consider it necessary that these employees undergo security clearances?
l l 1. If not, why not?
l
- 2. If yes, what level of clearance (i.e., Q)?
(i) Explain the basis for the answer.
. 3. Will the requirement for such clearance require enabling legislation because of infringement of such as right-to-work and right-to-privacy?
Answer.
IX. As noted in the Preamble to interrogatories V-XII, personnel security clearances are but one of the elements of DOE safeguards system. Individuals with access to or control of SNM would be granted clearances as appropriate under DOE Order 5632.2, " Physical Protection of Special Nuclear Materials." No new authorizing legislation would be necessary as authority for a security clearance program exists under Sections 145 and 161 of the Atomic Energy Act of 1954 as amended.
At the CRBRP Plant site all TVA employees will be subject to a security investigation consisting of a national as,ency check as referenced in the PSAR Section 13.7.
Interrogatory.
X. With respect to the DOE including guards, at all CRBR related facilities and those associated with transportation, does the Applicant consider it necessary that these employees undergo psychological profile tests?
- 1. If not, why not?
- 2. If yes, what particular test (s) would you consider i necessary?
l l (1) Explain the basis for the answer.
.. 3. Will the requirement for such testing require enabling legislation because of invasion of privacy and infringement of 1st Amendment rights?
Answer.
X. Experience in DOE facilities has not indicated that psychological profile tests are necessary. Other elements in the Applicants' safeguards system (e.g. , access controls ,
searches, intrusion detection devices, personnel security clearances and periodic reinvestigations, and several cleared personnel escorting shipments) provide assurance of reliable employee performance without the necessity for requiring psychological profile tests. Should, however, such tests be deemed advisable, legal authority for psychological testing as part of a security clearance program exists under Sections 145 and 161 of the Atomic Energy Act of 1954, as amended. Ongoing work in these areas includes a past employment behavior study related to security of nuclear programs and facilities.
Interrogatory XI. Does the Applicant consider that intelligence informa-tion gathering is an essential part of an adequate safe-guards system?
i
- 1. If not, why not?
- 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, transport guards, and reaction forces?
Answer.
XI. Information about planned malevolence is part of an adequate safeguerds system. Emergency protective measures applicable to sites and transportation of SNM would be determined, in part, by this information. Such information would be collected by local law enforcement, the FBI, and CIA (as appropriate under their respective charters), and furnished for use to the organization that coordinates the action of fixed-site guards, transportation guards, and reaction forces.
Interrogatory.
XII. Considering your answers to the above safeguard f related questions, does the Applicant view the development of an adequate system of safeguards will require the devel-opment of an organization that would be comparable to a national police force?
l
- 1. If not, why not?
Answer.
XII. An organization comparable to a national police force will not be required for the Applicants' facilities. The systematic approach to safeguards by the Applicants provides adequate protection without such a police-type organization.
Interrogatory.
XIII. 1. The AEC's Special Safeguard Study (the Rosenbaum Report) of April 29, 1974, concluded with the following:
Even though safeguard regulations have just been revised and strengthened, we feel that [the] new regulations are inadequate and that immediate steps should be taken to greatly strengthen the protection of special nuclear materials. We hope that this paper will contribute in a positive way to the speedy implementation of such steps.
(i) Does the Applicant agree that this was a valid conclusion as of April 29, 1975? If not, explain in detail the basis for the answer.
(ii) Does the Applicant agree that this is a valid conclusion today? If not, explain in detail the basis for the answer.
- 2. With respect to the level of threat to facilities t
and SNM, the Rosenbaum report postulated a maximum credible consisting of 15 highly trained men, three of i
whom might be " insiders," employed by the licensee I
target firm.
l l
, Does the Applicant agree that this is a representation of the maximum credible threat to (a) the CRBR; (b) fabricating facilities fabricating CRBR fuel; (c) shipments of plutonium from the ERDA stockpile to the fuel fabricating plant; and (d) shipment of fuel from the fabricating facility to the CRBR? If not, explain fully the basis for any disagreement.
- 3. A 1975 draft of the Executive Summary of the Security Agency Study stated:
To estinate the credible threat, the office of Nuclear Materials Safety and Safeguards researched 19 relevant studies and conducted 9 interviews with individuals and groups of professional analysts from the FBI, the intelligence community, the Department of Defense and State and local law enforcement agencies.
What emerged from this was a consensus estimate that an external threat group will probably number about 6 - 8 persons and very likely not exceed 12 persons.
[A] credible internal threat, for safepards purposes, is estimated to consist of 2 - 3 persons in collusion.
0bes the Applicant agree that this is representative of a credible threat to (a) the CRBR; (b) fabricating facilities fabricating CRBR fuel; (c) shipments ,
of plutonium from the ERDA stockpile to the fuel fabricating plant; and (d) shipment of fuel from the fabricating
l 1
facility to the CRBR? If not, explain fully the basis for and disagreement.
- 4. The U. S. Marshals Service in Security of Special Nuclear Materials (October 1975) began with the statement:
"The image of security is all that's wanted." This quotation from a study entitled " Private Security and the Public Interest" effectively illustrates one problem with guard forces employed by the private sector of the nuclear industry throughout the United States:
too often the image has little substance behind it.
Does the Applicant agree with this statement? If not, explain fully the basis for any disagreement.
- 5. Mr. Charles Brennan, former Assistant Director of the FBI for Domestic Intelligence recently stated:
The safeguards are a joke. The companies involved are interested mostly in saving money. They're doing only the bare minimum of security required by the Nuclear Regulatory Commission.
Does the Applicant agree with this statement? If not, explain fully the basis for any disagreement.
- 6. In transcripts of a February 13, 1976 meeting between NRC and NRDC, the NRC staff indicated (p. 4950) the current safeguards security system is based on a threat that provides for the guards at the site to effectively overcome two aggressors and to withstand for certain periods of time larger numbers of aggressors (up to 10) until local police
. or other law enforcement agencies can respond. There have to be 10 armed people on site within 30 minutes, 8 within 25 minutes, 6 within 20 minutes, and four within 15 minutes.
The armed guards and aggressors are assumed to be armed with small weapons.
(i) Does the Applicant believe the above aggressor force postulated by the NRC staff is representative of the maximum credible threat against (a) ERDA Pu inventories; (b) CRBR fuel fabrication facilities; (c) the CRBR; (d) shipments of Pu between (a) and (b); and (e) shipments of Pu between (b) and (c) ? Explain fully the basis for the answer.
(ii) Considering the fact that the guards may be surprised, or one of the guards may be part of the aggressor force, does the Applicant believe the 2 guard force is adequata to overcome a two man aggressor force? If not, explain in detail the basis for the answer.
(iii) Does the Applicant agree that it is credible that the aggressors would be armed with (a) automatic weapons; (b) bazookas; (c) grenades
, and grenade launchers; (d) anti-aircraft weapons; (e) heat seeking missiles; (f) or some other
. combination of the above? If not, explain in detail the basis for the answer.
- 7. An armored car in Montreal was recently robbed by several men armed with an anti-aircraft weapon. Does the Applicant believe a threat of similar size, training, and armament is credible against (a) ERDA Pu inventories; (b) CRBR fuel fabrication facilities; (c) the CRBR; (d) shipments of Pu between (a) and (b); (e) shipments of Pu between (b) and (c)?
Answer.
XIII. 1. The draft study was intended to address NRC requirements for licensed facilities as of April 1974. The Applicants, as potential licensees, are not in a position to address the adequacy of these NRC requirements.
2&3. Refer to the Preamble (to Interrogatories V
- XIII) for a general discussion of the " design basis threat." Specific discuccion of " maximum credible" threats to CRBRP and its peripheral facilities are not meaningful for reasons explained in the Preamble.
- 4. The Applicants do not agree that image is everything, although " image" does provide a valid psychological deterrence to malevolent acts and should not be ignored. The Applicants' posture with respect to guard forces is that they are fully integrated with the other l
elements of the safeguard and security system to effectively l
l l
l 46 -
address protection requirements. In order to assure that guard forces remain effective in meeting postulated threats, their response adequacy is tested routinely as a force, and individual guard force members are periodically re-tested as to training levels and physical condition.
- 5. The Applicants are not familiar with Mr.
Brennan's statement, the context in which it was was made, or the basis for it. The Applicants are not in a position to judge the attitude of industry in connection with compli-ance with NRC requirements.
6&7. Refer to the Preamble (to Interrogatories V
- XIII) for a general disc:ssion of the " design basis threat."
l l
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. . 3 ,
. UNITED STATES OF AMERICA NUCLEARREGutATORYCOMb1SSION In the Matter of U. S. DEPARTMENT OF ENERGY DOCKET N0l 50-537 PROJECT MANAGEMENT CORPORATION, ,
and TENNESSEE VALLEY AUTHORITY
. AFFIDAVIT OF EDWARD F. PENICO ,.
Edward F. Penico, being duly sworn, deposes and says,as follows:
- 1. That he is employed as Security Consultant for the CRBRP Project.. and that he is duly aut'horized to answer Interrogatories IV 1-4 .
of the eighth set of Interroga, tories. -
That the above entioned and attached answers are true and,
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correct to the best of his knowledge and belief. ,_,
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SUBSCRIBED and SWORN to before me .
this 8d days of $44,1[ 1982
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'V Commission Expires April 23,1984 e e .9 m.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the statter of .)
Department of Energy .)
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY .)
AFFIDAVIT OF Barry Dalinsky, being culy sworn, deposes and says as follows:
- 1. That he is employed as Acting Chief, Personnel Clearances Branch, Office of Safeguards and Security, U.S. Departnent of Energy, and that he is duly authorized to answer interrogatories numbered IX, 3 and X in the eighth set.
- 2. That the above-mentioned and attached answers are true and correct to' the best of his knowledge and belief.
AAt/
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$UBSCRIBED and SWORN to before me this A 9 day of M o c 2 , 1982.
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Notary #ublic l
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l PATRlCA G. Ct.MBEDO NOTA 47 PUBUC STATE CF MARYLAND t h
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tiMISSION In the matter of .)
Department of Energy ,)
- DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,)
AFFIDAVIT OF John Stewart, being duly sworn, deposes and says as follows:
- 1. That he is employed as Program Analyst, Office of Safeguards and Security, U.S. Department of Energy, and that he is duly authorized to answer interrogatory number XI in the eighth set.
- 2. That the above-mentioned and attached answer is true and correct to the best of his knowledge and belief.
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SUBSCRIBED and SWORN to before me this ,79 day of 4 %/ / , 1982.
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DOCKET MO. 50-537 PRGJECT MANAGEMENT CORPORATIOW and,)
I'""ESSEE J VAI.tEY E'THORITY ,)
AFFIDAVIT OF Thomas H. Isaacs, being duty sworn, deposes and say. .> (clienii.
1_ That he k cantoyed as Denuty Dire _ctor. Office of Safeguards and Security, U.S. Depart,ent of Energy, and that he is duly auth : zed to answer Prensbie to interrogatories Y through XIII, responses to questions V.1, V.4, VIII.2-6, XII, Yllt.1-7 in the eighth set.
- 2. That the above-sentioned and attached answers are true and i
corrut to the best of his knowledge and belfef.
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NUCLEAR REGULATORY COMMISSION
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In the matter of .
Department of Energy .) DOCKET NO. 50-537 :
FROJECT MANAGEMENT CORFORATION and,) ,
TENNgSSEE VALLEY AUTHORITY .)
AFFIDAVIT OF Major General William W. Hoove.r, USAF, being duly sworn, deposes and says as follows:
. L. That he is employed as Deputy Assistant Secretary for Military Application, U.S. Department of Energy , and that he is duly authorized to answer interrogatories numbered I.1-8, VI.1-5, i
~ IIII.3 e and d, XIII.6 d and e in the eighth set. ;
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- k to the best of his knowledge and belief.
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.4' Y day of M >r /L.._, 1982.
SUBSCRIBED and SWORN to before me this s
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My Consission expires , 19_. .
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y, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ,)
Department of Energy ,)
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,)
AFFIDAVIT OF Dr. F. C. Gilbert, being duly sworn, deposes and says as follows:
- 1. That he is employed as Deputy Assistant Secretary for Nuclear Materials, Defense Programs, U.S. Department of Energy, and that hw is duty authorized to update the replies to Items II.1, II.3, III.1, III.2, and III.3, in the eighth set of interrogatories propounded by the Natural Resources Defense Council, et. al.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
f v Signature SUBSCRIBED and SWORN to before me this f.1/ day of /fo/r,L. , 1982.
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My Commission expires , 19_.
PATR!CA G. CUM 4ERC
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of .)
Department of Energy ,)
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY .)
AFFIDAVIT OF Robert L. Woolley, being duly sworn, deposes and says as follows:
- 1. That he is employed as Licensing Manager, Plant Development Division, Office of Nuclear Energy, U.S. Department of Energy, and that he is duly authorized to answer interrogatory numbered III.Sa in the eighth set.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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Signature SUBSCRIBED and SWORN to before me this .jC day of n wlf , 1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- In the matter of: )
U. S. DEPARTMENT OF ENERGY
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DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION, and )
TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT of Douglas Hornstra, PMC, being duly sworn, deposas and says as follows:
- 1. That he is employed as Reactor Engineer, Engineering Division, CRBRP/P0 and that he is duly authorized to answer interrogatories numbered II.2, III.5b in the Eighth set.
- 2. That the above-mer.tioned and attached answers are true and correct to the best of his knowledge and belief.
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M $sJ Signaggre SUBSCRIBED and SWORN to before me this /// y of #1 1982.
WP /' 6'f!R NotaryPublic ,
My Commissi:n Expires April 28,192.; .-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ,)
Department of Energy ,)
DOCKET No. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,)
AFFIDAVIT OF William M. Hartman, being duly sworn, deposes and says as follows:
- 1. That he is employed as Nuct. ear Engineer, Office of Reactor Research and Technology, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered 16 and 20 in the first set and III.4 in the eighth set.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
A.4k k 4LA Signature SUBSCRIBED and SWORN to before me this /6 day cf /lofc,L ,1982.
ll W*o $. 5 Ass Notary Public l
My Commission expires , 19_.
PATRIQA o CUM 8 ERG NOTARY PUBUC STATE CF MARYtAm My Comenission gag,, jug, y, y yy
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IRICLEAR REGULATORY COMISSION 1
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DocKEI NO. 50-537 PR(VEC1 %WAGLMENT CORPORAT10W and,1
- --- -- MMMESSEE YALLEY A1TTRORITY .)
affluMTT1F"-- TE5 mas H. Isaacs, being duly sworn, deposes and says as follows:
- 1. That he is employed as Deputy Director Of fice of Safeguards and Security, U.S. Department of Energy, and that he is duly avtnorized to answer interrogatory number if, Contention 5 ,
1
-in the sixteenth set. _ . . .
- 2. That the above-mentioned and attached ansa.er is true and correct to the best of his Knowledge and belief. 7
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ,)
Department of Energy ,)
DQCKEI.NO, 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,)
- AFFI0AVIT OF William Knauf, being duly sworn, deposes and says as follows:
- 1. That he is employed as Program Analyst, Office of Safeguards and Security, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered V.2, V.3, and VII in the eighth set.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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Sig?xja re SUBSCRIBE 0 and SWORN to before me this S g_ day of //pa , l. ,1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
)
In the Matter of )
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UNITED STATES DEPARTMENT OF ENERGY )
)
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
)
TENNESSEE VALLEY AUTHORITY )
(Clinch River Breeder Reactor Plant) )
)
I CERTIFICATE OF SERVICE I
Service has been effected on this date by personal delivery or first-class mail to the following:
- Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Co==ission Washington, D. C. 20545 Dr. Cadet H. Hand, Jr.
Director Bodega Marine Laboratory University of California P. O. Box 247 l Bodega Bay, California 94923 l l
- Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545 ,
- Daniel Swanson, Esquire
- Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (2 copies)
- .. o i l
, -2_
1
- Atomic Safety & Licensing Appeal Board l U. S. Nuclear Regulatory Commission Washington, D. C. 20545 '
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Co= mission Washington, D. C. 20545
- Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Co==ission Washing:en, D. C. 20545 (3 copies)
William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)
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Mr. Joe H. Walker !
i 401 Roane Street l Harriman, Tennessee 37748 '
Ellyn R. Weiss Harmon & Weiss Wa hi o D b. '2 bb6 l
bi -
l 3-Lawson McGhee Public Library 500 West Church Street
. Knoxville, Tennessee 37902 William E. Lantrip, Esq.
Attorney for the City of Oak Ridge Mhnicipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq.
Warren E. Bergholz, Jr., Esq.
U. S. Department of Energy 1000 Independence Ave., S. W.
Room 6-B-256, Forrestal Building Washington, D. C. 20585 (2 copies) :
- Eldon V. C. Greenberg Tuttle & Taylor 1901 L Street, N. W., Suite 805 Washington, D. C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 A
Geor M . Edg F ,
Attorney for Proj ect .Managsment Corporation -
DATED: April 30, 1982 f r
- / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C. !
- / Denotes hand delivery to indicated address.}