ML20052G983
| ML20052G983 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/30/1982 |
| From: | Mizuno G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| Shared Package | |
| ML20052G984 | List: |
| References | |
| NUDOCS 8205190214 | |
| Download: ML20052G983 (7) | |
Text
4/30/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
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U.S. DEPARTMENT OF ENERGY
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Docket No. 50-537 PROJECT MANAGEllENT CORPORATION
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant) )
NRC STAFF'S UPDI,TED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL FIRST SET OF INTERROGATORIES TO THE STAFF DATED NOVEMBER 18, 1975 Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Comission Staff (Staff) hereby updates its December 12, 1975 and February 24, 1976 responses to Intervenors', Natural Resources Defense Council, Inc. and the Sierra Club First Set of Interrogatories to the Staff filed on November 18, 1975. Attached hereto are the Staff's answers to NRDC's interrogatories, together with the affidavits of those individuals who prepared the answers.1/
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:
A)- Provide the direct answer to the question.
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The affidavits of Mr. Bell and Mr. Miller are unsigned. However, a copy of their signed and notarized affidavits will be filed shortly.
B205190214 820430 PDR ADOCK 05000537 o\\l 0
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 particular 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.
l 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 intends to engage in any further, ongoing 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 the 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 answer 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.
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C)
There were no principal documents and studies specifically examined but not cited in (b) unless otherwise noted.
1 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.
E)
The Staff is not presently engaged in nor intends to engage in any further, on-going research program which may affect the Staff's answer unless otherwise noted.
F)
At this time, the Staff has not detennined 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 the contentions. When an old contention number appears in the interrogatory question or answer, the new conten-tion number will be indicated in parentheses.
Respectfully submitted,
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Gea'ry. Mizuno Counsel for NRC Staff Dated at Bethesda, Maryland this 30th day of April, 1982
t NRC STAFF'S ANSWERS TO NRDC'S INTERR0GATORIES The NRC Staff has determined that the previous response to Interrogatory #11 is still applicable and needs no updating.
The following interrogatories relate to Contention 8 (renumbered as 11):
Interrogatory 9 What is NRC's current position with respect to the validity of the guideline values for bone and lung exposure assumed by PMC?
Response
The dose guidelines used by the NRC for reactor siting are developed by the Commission's staff with consideration given to both the nuclear industry (in this case PMC) and public comments.
The present dose guidelines are under review and any statement about the CRBR guidelines at this time would be premature. However, when the review is complete, we will issue a response to the above question.
Interrogatory 10 Within the framework of the existing standards, what has NRC determined to be the "As Low As Practicable" (ALAP) exposure due to routine releases of actinides from LMFBR power plants? What has NRC determined to be the ALAP exposure due to radioactive releases of other radioactivity form LMFBR power plants?
Response
The Staff's December 12, 1975 response to this Interrogatory is amended by deleting the term, "as low as practical", and substituting the term, "as low as reasonably achievable (ALARA).
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
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 JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering Interrogatory #11 of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.
John V. Nehemias Subscribed and sworn to before me this day of April, 1982.
Notary Public My Comission expires:
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD P
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 LARRY W. BELL I, Larry W. Bell, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Nuclear Engineer, Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering Interrogatory
- 9 of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.
U RRY W. BELL Subscribed and sworn to before me this day of April,1982.
Notary Public My Commission expires:
t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
)
l UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 i
PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY 1
(Clinch River Breeder Reactor Plant) )
i AFFIDAVIT OF CHARLES L. MILLER I, Charles L. Hiller, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Eff1 bent Treatment Systems Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.
2.
I am duly authorized to participate in answering Interrogatory #10 of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.
CHARLES L. MILLER Sub:cribed and sworn to before me
- thi, day of April,1982.
Notary Public My Comission expires:
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