ML20052C498

Updated Response to NRDC & Sierra Club 760817 Request for Admissions.Certificate of Svc Encl

ML20052C498
Person / Time
Site:	Clinch River
Issue date:	04/30/1982
From:	Gilbert F, Hartman W, Hornstra D JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
To:	National Resources Defense Council
References
NUDOCS 8205050053
Download: ML20052C498 (11)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY ) Docket No. 50-537

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(Clinch River Breeder Reactor )

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APPLICANTS' UPDATED RESPONSE J c TO INTERVENORS', \l A.,. e NATURAL RESOURCES DEFENSE COUNCIL, AND SIERRA CLUB, AUGUST 17, 1976 ING.kA,D

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REQUEST FOR ADMISSIONS TO THE APPLICANTS /. i Pursuant to 10 CFR S 2.742 and the Board's Pre-hearing Conference Order dated 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 Intervenors', Natural Resources Defense Council, Inc. , and the Sierra Club, August

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17, 1976 Request for Admissions to the Applicants.-

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,/ Applicants previously responded on August 31, 1976.

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@205050053 820430 PDR ADOCK 05000537 C PDR l

Admission.

1. There are no significant quantities of separated domestic power reactor plutonium available for use in the CRBRP.

Response.

Applicants neither admit nor deny, since the Board's April 6, 1982 ruling and April 14, 1982 Order in regard to NRDC Contention 17 have obviated a response.

Admission.

2. There are no significant quantities of separated foreign plutonium known to be available to fuel the CRBRP.

Response.

See response to 1. above.

Admission.

3. It is anticipated that all plutonium to be used to fabricate fuel for the CRBRP through FY 1988 will come from ERDA stockpiles.

Response.

See response to 1. above.

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Admission.

4. There was approximately 550 kg of fuel grade plutonium available as of March, 1976 for use in the CRBR, FFTF and the ZPR programs.

Response.

See response to 1. above.

Admission.

5. The exact location of this 550 kg inventory is known to ERDA but is presently classified.

Response.

Applicants can neither admit nor deny this state-ment since the locaticn from which the plutonium for CRBRP fuel will be obtained has not yet been determined. See Applicants' Updated Response to NRDC Interrogatory Set 8, III S.a). See also response 1. above.

Admission.

6. ERDA as of March 1976 also had about 3690 kg of fuel grade Pu as scrap and irradiated fuel which can be processed to useable forms and made available for ERDA pro-l grams.

Response.

See response to 1. above.

e Admission.

7. The location as of March 1976 of these scrap and irradiated fuel inventories is as follows:

Irradiated N Reactor Fuel Richland, Wa. 2500 kg Irradiated Fuel Savannah River, 450 S.C.

Reactor Blanket Shippingport, Pa. 140 Scrap Various locations 600 Response.

See the response to 1. above.

Admission.

8. Other materials are added to this category as new scrap is generated, programs are completed or elimi-nated, spent fuel is generated, etc.

Response.

See the response to 1. above.

Admission.

9. The most likely CRBR fuel fabricator is Babcock and Wilcox Nuclear Material Division in Leechburg, Pennsylvania.

Response.

Denied. The most likely fuel fabricator is the Westinghouse Hanford Company, operating the Secure Automated 4

Fabrication Line in Richland, Washington.

Admission.

10. Fuel for the CRBR will most likely be shipped by DOE under DOE safeguards.

Response.

Admitted.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ,) (

Department of Energy ,)

DOCKET NO. 50-537 l PROJECT MANAGEMENT CORPORATION and,) I i

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 he is duty authorized to update the replies to Items 1-8 '

in the Natural Resources Defense Council's August 17, 1976 request for Admission concerning Contention 9. l

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

Signature (

SUBSCRIBED and SWORN to before se 'this h/ day of M ##<d- ,1982.  !

?M b mba 1 Notary' Public ,g l

My Commission expires , 19_. l l

PATWCIA G. CR M BERO WARY PUBUC STATE OF MARY 1AND My Commission Empires My 1,1982

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 Nuclear Engineer, Office of Reactor Research and Technology, U.S. Department of Energy, and that he is duly authorized to execute the responses on behalf of the Applicants to the NRDC's August 17, 1976, request for Admission Contention 9, number 9; and NRDC's August 13, 1976, request for Admission Contention 5, number 25.

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

Signature SUBSCRIBED and SWORN to before me this N day of A pa e L ,1982.

fis]lTe (3. 0 mJap Notary Ptiblic U My Commission expires , 19_.

PATRICIA G. CILIMBERG NOTARY PUBLIC STATE CF MARYLAt:0 My Commitsion Empires July 1,1902

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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U.S. DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION and

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TENNESSEE VALLEY AUTHORITY )

AFFIDAVIT OF DOUGLAS HORNSTRA, PMC Douglas Hornstra, being duly sworn, deposes and says as follows:

1. That he is employed as Reactor Engineer, Engineering Division, CRBRP/P0 and that he is duly authorized to answer the response on behalf of the Applicants to the NRDC's Admissions to old Contention 9, Admission number 10, dated 8/17/76.

2. That the above-mentioned and attached response to NRDC's Admission is true and correct to the best of his knowledge and belief.

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SUBSCRIBgEand SWOR ob ore me this /4 day of ,1982.

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No';aryjublic My ConYmission Expires April 28,1984

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

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TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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CERTIFICATE OF SERVICE 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 Commission Washington, D. C. 20545 Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory Universitv of California P. O. Box'247 Bodega Bay, California 94923

• Mr. Gustave A. Linenberger Atomic Safety & Licensing Board l U. S. Nuclear Regulatory Commission Washington, D. C. 20545 ,

• Daniel Swanson, Esquire

• Stuart Treby, Esquire Office of Executive Legal Director l U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (2 copies) l l

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• Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545

• Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20545  !

• Docketing & Service Section Office of the Secretary -

U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (3 copies)

William M. Leech, Jr., Attorney General l William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway '

14ashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire i Lewis E. Wallace, Esquire i 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)

• • Dr. Thomas Cochran Barbara A. Finamore, Ecquire '

Natural Resources Defense Council 1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 (2 copies)

Mr. Joe H. Walker 401 Roane Street

Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss t

1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006

3-Lawson McGhee Public Library i 500 West Church Street '

. Knoxville, Tennessee 37902 William E. Lantrip, Esq.

Attorney for the City of Oak Ridge Municipal 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

GeorgVL. EdgF Attorney for Project Management Corporation DATED: April 30, 1982

• / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.

• • / Denotes hand delivery to indicated address.

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