ML20053F016

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Forwards Signed & Notarized Affidavits of NRC Staff Who Participated in Updating Answers to Interrogatories & Requests for Admissions Prior to Apr 1977 or Who Answered NRDC & Sierra Club 820318 & 26 Interrogatories
ML20053F016
Person / Time
Site: Clinch River
Issue date: 05/17/1982
From: Swanson D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Breckenridge L
TENNESSEE, STATE OF
References
NUDOCS 8206100309
Download: ML20053F016 (76)


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May 17, 1982 certified By WI l

V vso7 Lee Breckenridge i

Assistant Attorney General i

450 James Robertson Parkway Nashville, Tennessee 37219 i

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In the Matter of I

UNITED STATES DEPARTMENT OF ENERGY PROJECT f!ANAGEMENT CORPORATION I

TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

Docket No. 50 537 I

Dear Ms. Breckenridge:

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Enclosed are copies of the signed and notarized affidavits of the NRC Staff j

who participated in updating answers to interrogatories and requests for admissions in the case prior to April,1977. Also included are the i

affidavits of those individuals who answered Natural Resources Defense l

Counsil, Inc. anet the Sierra Club Twenty-second Set of Interrogatories to I

Staff filed on March 18, 1982 and Intervenors', Natural Resources Defense Council, Inc. and Sierra Club, Twenty-third Set of Interrogatories and

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Request to Produce to the Staff filed on March 26, 1982.

I Sincerely, l

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Daniel T. Swanson l

Counsel for NRC Staff I'

Enclosures:

as stated cc: Service List with enclosures j

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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I UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h)

TENNESSEE VALLEY AUTHORITY i

(Clinch River Breeder Reactor Plant) h a

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

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I am employed by the U.S. Nuclear Regulatory Comission as a

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Reactor Engineer, Clinch River Breeder Reactor Program Office.

Office of Nuclear Reactor Regulation.

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I am duly authorized to participate in answering the Request for 2.

Admissions pertaining to Contention 2 (renumbered as 1) #81 through If

  1. 95 and I hereby certify that the answers given are true to the i

ll best of my knowledge,

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P Cardis L. Allen

,I Subscribed and sworn to before me thisg day of. May 1982.

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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD d.

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In the Matter of

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Docket No. 50-537 9),

PROJECT mat 4AGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

I AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office, i

Office of Nuclear Reactor Regulation.

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I 18, 1982 I am duly authorized to participate in answering the March 2.

9th Request for AdmissionsSection II, concerning Contention 3 (re-li I

numbered as 2) #1 through #6 and I hereby certify that the anrwers given are true to tha best of my knowledge.

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wu iJAD Subscribed and' sworn to before me this day of. May,1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CONIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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U.S. DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

l TENNESSEE VALLEY AUTHORITY l

I 4'.,linch River Breeder Reactor Plant) h AFFIDAVIT OF CARDIS L. ALLEN l

I, Cardis L. Allen, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, i

Office of Nuclear Reactor Regulation.

l 2.

I am duly authorized to particip.Le in answering the August 13, i

1976 Request for Admissions concerning contention 2 (renumbered as 1) l-il through #5 and I hereby certify that the answers given are true l'

to the best of my knowledge.

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Subsc ibed and sworn to before me 2

this W day of May,1982.

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In the Matter of 1'

UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

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(Clinch River Breeder Reactor 1,

Plant) i AFFIDAVIT OF ROBERT J. DUBE 1

I, Robert J. Dube, being duly sworn, state as follows:

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I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section,

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Fuels Facilities Safeguards Licensing Branch, Division of Safe-i guards, Office cf Nucler.r ihterial Safety and Safeguards.

i I am duly authorized to participate in answering the Request for il) 2.

Adnissions pertaining to Contention 5 (renumbered as 4) #1 through Il 38 and I hereby certify that the answers given are true to the i

best of my knowledge.

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ROBERT J. DCBE Subscribed and s$orn to before me p6 April,}982.

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l'j In the Matter of ll ll Docket No. 50-537 UtlITED STATES DEPART!!ENT OF ENERGY t

i PROJECT ttAtlAGEMENT CORPORATION ll TENilESSEE VALLEY AUTHORITY

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(ClinchRiverBreederReactor ll Plant) i AFFIDAVIT OF HOMER LOWENBERG

'l I, Homer Lowenberg, being duly sworn, state as follows:

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I am employed by the U.S. Nuclear Regulatory Comission as Chief Engineer, Office of Nuclear Material Safety and Safeguards.

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I am duly authorized to participate in answering the Requests for I!,:

AdmissionspertainingtoContention9(renumberedas6)#1through 1\\

10 and I hereby certify that the answers given are true to the best of my knowledge.

HOMER LOWENBERG l

Subscribed and' sworn to before me 1

!i this 3Pday of April,1982.

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In the Matter of

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U.S. DEPARTMENT OF ENERGY h

Docket No. 50-537

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PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor Plant) ))

1 AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River ij?

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Breeder Reactor Program Office Office of Nuclear Reactor Regulation.

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I am duly authorized to participate in answering the September 16, 1976RequestforAdmissionsconcerningcontention5(renumbered as 4) #50 and I hereby certify that the answers given are true to the best of my knowledge.

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Subscribed and sworn to before me this $ day.cf May,1982.

0 f.dd Notary Public f // M My Comission expires:

o UNITED STATES OF AMERICA NUCLEAR REGULATORY C0ffilSSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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i UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION p

TENNESSEE VALLEY AUTHORITY g

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(Clinch River Breeder Reactor Plant) i AFFIDAVIT OF ROBERT J. DUBE i

I, Robert J. Dube, being duly sworn, state as follows:

9 1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, l

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 the Request for Admissions pertaining to Contention 5 (renumbered as 4) #39 through 56 and I hereby certify that the answers given are true to the best of my knowledge.

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ROBERT J. DUBE Subscribed and' sworn to before ne this 7b day of April,1982.

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U.S. DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITH

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AFFIDAVIT OF MICHAEL BENDER 8

I, Michael Bender, being duly sworn, state as follows:

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1.

I am employed by the U.S. Nuclear Regulatory Commission (NRC) as a Consultant through a contract between the Clinch River

'f Breeder Reactor Program Office, NRC, and Brookhaven National i

Laboratories.

2.

I am employed by the Brookhaven National Laboratories as a senior Scientist in the Medical Department.

l 3.

I am duly authorized to participate in answering the September 16, 1976 Request for Admissions concerning contention 8a (re-numbered as 11) 421 through I36, 441 and i42 and I hereby certify that the answers given are true to the best of my l

knowledge.

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MICHAEL BENDER Subscribed and sworn to before me this (r # day of May, 19 82.

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In the Matter of

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i U.S. DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY ll i

(ClinchRiverBreederReactorPlant)ll f

AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows:

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I am employed by the U.S. Nuclear Regulatory Comission as a Senior Health Physicist, Radiological Assessment Branch, Division i

of Systems Integration, Office of Nuclear Reactor Regulation.

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I am duly authorized to participate in answering the September 16, 1976RequestforAdmissionsconcerningcontention8a(renumbered as 11) #36 through f40 and I hereby certify that the answers given are true to the best of my knowledge.

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L b Q4 V. NEhEMIAS Subscribed and sworn to before me this ay of May, 1982.

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U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 l

PROJECT MANAGEMENT CORPORATION l

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TENNESSEE VALLEY AUTHORITY l

i (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL' M. MORRIS I

I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Off'ce, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering the Request for Admission #1through#30concerningcontention3(renumberedas2) and I hereby certify that the answers given are true to the best of my knowledge.

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BILL M. MORRIS l;

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UNITED STATES OF N' ERICA HUCLEAR REGULATORY COMMISSION BEFORE THE _AT0tilC SAFETY A!!D LICENSIFG P07PD 4' p

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In the Matter of I

9 Docket No. 50-537 UtilTED STATES DEPARTMENT OF ENERGY h

Pr00ECT FMAGEPENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

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(Clinch River Bretter Reactor Plant) 2

,i AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

I an employed by the U.S. Nuclear Regulatory Comission as a 4

1.

l Section Chief of Regulatory Activities and Analyses Section, Fuel Facility Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards, i

I am duly authorized to participate in answering the Request for 2.

Admissions pertaining to Contentica 2 (renumbered as 1) d6 through 30 and I hereby certify that the answers given are true to the best of my knowledge.

4 ll ROBERT J. 'DUBE t

Subscribed and snorn to before me this ~ TAT c,f ' April, 1982.

totIRT F. Ara!Y, Je.

N MOMY NBUC STATE OF MARYLAND ry Ccmission expires: Jfg/,;4it "rc'

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ATOMIC SAFETY AND LICENSING kOARD l

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In the Matter of Docket No. 50'-537 UNITED STATES DEPARTMENT OF ENERGY

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l PROJECT MANAGEMENT CORPORATION l

TENHESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )I f,

AFFIDAVIT OF CARDIS L. ALLEN i

i I,Cardis L. Allen, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office.

Office of Nuclear Reactor Regulation.

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I am duly authorized to participate in answering the Requests for 2.

i t Admissions pertaining to Contention 2 (renumbered as 1), #31 through #80 and I hereby certify that the answers given are true to the best of my knowledge.

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Cardis L. Allen i

bed and sworn to before me Subscr $ day of, May,1982.

I this OfL1 Notary PubTic y

My Conaission expires: M4 1

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NUCLEAR REGULATORY COMMISSION -

w BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I

In the Matter of l

ll'I Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) ),

AFFIDAVIT OF EDWARD F. BRANAGAN, JR I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I an employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

i 2.

I am duly authorized to participate in answering Interrogatories fl.

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  1. 10,ill,and#12pertainingtoContention8(renumberedas11)of 1

the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge.

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~., f-Edward F. Branagan, Jr. /-

t Subscribed and sworn to before me this/g)/4da'y'ofMay,1982.

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My Comission expires: 7// h.q

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NUCLEAR REGULATORY C0Ft41SSION.,.

BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD i

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UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION j

i TENNESSEE VALLEY AUTHORITY

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(ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF BILL H. MORRIS i

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1, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section i

Leader of the Technical Review Section, Clinch River Breeder Reactor 1

Program Office, Office of Nuclear Reactor Regulation.

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- i Il I am duly authorized to participate in answering Interrogatory IV, 2.

  1. 1 of the 22nd Set and I hereby certify that the answers given are -

true to the best of my knowledge.

h h /M-Wh d Bill M. Morris i

Subscr bep and sworn to before me this ff day of May, IP82.

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My Comission expires:

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PROJECT MANAGEMENT CORPORATION 1

TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF JOHN V. NEHEMIAS i

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.

i I am duly authorized to participate in aaswering Interrogatories #2 2.

through #5 of Section II of the 22nd Set and I hereby certify that l

l the answers given are true to the best of my. knowledge.

Lat/ Rs-O n V. Nehemias Subscribed and sworn to before me this ff day of May,1982.

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//M1 Notary PubliTc My Comission expires:

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.'I.'

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l))l i

In the Matter of l

Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY l

PROJECT MANAGEMENT CORPORATION J

j TENNESSEE VALLEY AUTHORITY g

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(Clinch River Breeder Reactor j

Plant)

AFFIDAVIT OF HOMER LOWENBERG 1 Homer Lowenberg, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as Chief Engineer, Office of Nuclear Material Safety and Safeguards.

I am duly authorized to participate in answering Interrogatory #1(a) 2.

and (b) of the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge.

HOMER LOWENBERG Subscribedand'sworntobeforeme this 3 e day of. April, 1982.

Wh. w 'i o --i b u NotargPublic My Comission expires:

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)i UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 I

PROJECT MANAGEMENT CORPORATION

)1 TENNESSEE VALLEY AUTHORITY i

(Clinch River Breeder Reactor h

Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1.

I.. employed by the U.S. Nuclear Regulatory Comission 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 Interragatories 41 and #20 of the 23rd Set and I hereby certify that the answers given are true to the best of my knowledge.

WAl ROBERT J. DLKE SubscrW B

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In the Matter of

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UNITED STATES DEPARTHENT OF ENERGY l

Docket No. 50-537 9)?

PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor j

Plant)

AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows:

1 1.

I am employed by the U.S. Nuclear Regulatory Comission as a Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-l guards, Office of Nuclear Material Safety and Safeguards.

2.

I am duly authorized to participate in answering Interragatories

  1. 1 and #20 of the 23rd Set and I hereby certify that the answers given are true to the best of my knowledge.

WA2 i

ROBERT J. DD5E l

Subscribe and sworn to' before ne this D ay o,f April,1982.

Notary Public M/

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My Comission expires.

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NUCLEAR REGULATORY C0ttilSSION BEFORE THE ATOMIC SAFETY AND LICENSING SOARD

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UNITED STATES DEPARTHENT OF ENERGYl Docket No. 50-537 PROJECT ltANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHOP.ITY h

(Clinch River Breeder Reactor Plant) ),

AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehenias, being duly sworn, state as follow!:

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Senior Health Physicist, Radiological Assessment Branch, Divisien of Systems Integration, Office of Nuclear Reactor Regulation.

t I am duly authorized to participate in answering the July 28, 1976 2.

RequestsforAdmissionspertainingtoContention8a(renumberedas11)

  1. 1, #2, #13 through #16, #19 and #20 and I hereby certify that the answers given are true to the best of my knowledge.

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h'n. V. Nehemias ~

Subscr bed and sworn to before me this f/dayofMay,1982.

A b tj ffnn hotary Pub Hc My Comission expires: fj(

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UNITED STATES OF AMERICA:

NUCLEAR REGULATORY. COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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I UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant) )

l AFFIDAVIT OF MICHAEL BENDER l'

l I, Michael Bender, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Commission (NRC) 1.

s as a consultant through a contract between the Clinch River Breeder Reactor Program Office, NRC, and Brookhaven National Laboratories.

I am employed by the Brookhaven National Laboratories as a 2.

Senior Scientist in the Medical Department.

I am duly authorized to participate in answering the 3.

Request for Admissions pertaining to Contention July 28, 1976 8a (rinumbered e

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as 11, 14, 45, f8, 49, ill, 112, and 617 and I hereby certify that the answers given are true to the best of my knowledge.'

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b MICHAEL BENDER Subscribed and sworn to before me this 0 day of May, 1982.

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PROJECT MAMGEMENT CORPORATION) t Ii TENNESSEE VALLEY AUTHORITY I !

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Plant) jl AFFIDAVIT OF HOMER LOWENBERG_

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I. Homer Lowenberg. being duly sworn, state as follow 5:

If I am employed by the U.S. Nuclear Regulatory Comission as i

,1 1.

Chief Engineer. Office of Nuclear Material Safety and Safeguards.

i I am duly authorized to participate in answering the Requests for f

2.

Admissions pertaining to Contention 7 (renumbered as part of 11) il through #5 and I hereby certify that the answers given are true i

to the best of my knowledge, t'*& W HOMER LOWENBERG Subscribed and sworn to before me this %

  • day of April,1982.

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hotarf Public My Comission expires:

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UNITED STATES OF ERICA NUCLEAR REGULATORY COMillSSION.

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BE' FORE THE ATOMIC SAFETY AND LICENSING"B0ARD In the Matter of ll l

UNITED STATES DEPARTHENT OF ENERGY ll Docket No. 50-537 PROJECT ltANAGEttErlT CORPORATION I

l TENNESSEE VALLEY AUTHORITY l

l (Clinch River Breeder Reactor Plant) )l AFFIDAVIT OF EDWARD F. BRANAGAN, JR f

I, Edward F. Branagan, Jr., being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a ll Radiological physicist, Radiological Assessment Branch, Division of 1l Systems Integration, Office of Nuclear Reactor Regulation.

l 2.

I an duly authorized to participate in answering the July 28,1976 Requests for Admissions certaining to contention 7 (renumbered as 11) l

  1. 6 through #33; pertaining to contention 8a (renumbered as 11) f3 f6
  1. 7, #9, #10, #17 and #18; pertaining to contention Sc (renumbered as 11) #1 through #19 and I hereby certify that the answers given are true to the best of my knowledge.

l kd h

Edward F. Branagan, Jr.

/

Subscribed and sw"orn to before me gy/(iday of May,1982.

t

-/aw ~ kW2ame hotary Public~

g us woo &.u nxmirm: '7/e /f 7

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4 UNITED STATES OF ' AMERICA NUCLEAR REGULATORY COMMISSION 4

~;.

1

.i BEFORE THE ATOMIC SAFETY AND LICENSING _ BOARD In the Matter of

)I UNITED STATES DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION lll j

TENNESSEE VALLEY AUTHORITY l

(Clinch River Breeder Reactor Plant) )l t

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

1 l

I, Edward F. Branagan, Jr., being July sworn, state as follows:

i 1.

I am employed by the U.S. Nuclear Regulatory Comission as a -

Radiclogical Physicist, Radiological Assessment Branch, Division of Systems Integration. Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 10, #13, and #14 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

"Y Edward F. Branagan, Jr.

Subscribed and sworn to before me this

  • g day of May, 1982.

rz/h N/Jh Notary Public My Comission expires: 7d((p

~

UNITED STATES OF MiERICA T-NUCLEAR REGULATORY COMMISSION.'

l BEFORC THE ATOMIC SAFETY AND LICENSING 80ARD i

In the Matter of lll I

f UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION J

i TENNESSEE VALLEY AUTHORITY

/

)I (Clinch River Breeder Reactor l

Plant)

AFFIDAVIT OF HOMER LOWENBERG I

t I, Homer Lowerberg, being duly sworn, state,as follows:

l 1.

I am employed by the U.S. Nuclear Regulatory Comission as l

Chief Engineer, Office of Nuclear Material Safety and Safeguards.

1 i

l 2.

I an duly authorized to participate in answering Interrogatory i 17a II I

of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

1 NOA.

/

HOMER LOWENBERG Subscribed and sworn to before ce this 30* day of. April, 1982.

~.

hm,

-l u-AW Wotary Public My Comission expires:

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UNITED STATES OF AMERICA l

NUCLEAR REGULATORY COMt115510N

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2 BEFORE THE ATOMIC SAFETY AND LICENSINr BOARD In the Matter of ll)

I Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGYh PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor Plant) h)

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

I, Edward F. Branagan, Jr., being duly sworn, state as follows:

('

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Radiological Physicist, Radiological Assessment Branch, Division e

of Systems Integration, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories #84 2.

through #89 of the 20th Set and I hereby certify that the answers given l

l are true to the best of my knowledge.

AvW EDWARD F. BRANAGAN, JR.

/

Subscri ed and sworn to before me l

this - @ day.pf May,1982, ItAhi N /kLL, w NOTARY PuiillC

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My Comission expires:

UNITEDSTATESObMERICA NUCLEAR REGULATORY 'C0ttilSSION E.

BEFORE THE ATOMIC SAFETY AND LICENSINT BOARD

~

In the Matter of p

I U.S. DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY J

(Clinch River Breeder Reactor Plant) )l AFFIDAVIT OF MOHAN C. THADANI I, Mohan C. Thadani, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Accident Evaluation Branch, Division of Systems Integration Office of Nuclear Reactor Regulation.

I I am duly authorized to participate in answering Interrogatories 2.

(46, #47, #48, f49, #50, #51, f52, #53, #74, #75 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

a

[HANC.THADANI fA+

MO Subsc# IMay of May,1982.ribqd and.. sworn to before me this

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j d] rind l

N'otary Public My Cornission expires: [

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l E

d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'

^

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of p

I U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION ll TENNESSEE VALLEY AUTHORITY

)1 (Clinch River Breeder Reactor Plant) ')

AFFICAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

1.

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

l Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1 through #45, #49, #53, #82, and #83 of the 20th Set and I hereby a

certify that the answers given are true to the best of my knowledge.

i 2d RICHARD BECKER Subscr bed and iworn to before me this

  1. day of 'Nay,1982.

11 hl$

w Notary Public My Comission expires: 7///[A

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

s

~

BEFORE THE ATOMIC SAFETY AND LICENSING 1 0ARD

~

In the Matter of

)l UNITED STATES DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

l l

(Clinch River Breeder Reactor Plant) ll 4

AFFIDAVIT OF JERRY J. SWIFT 4

I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a f

Reactor Engineer, Clinch River Breeder Reactor Program Office,

't Office of Nuclear Reactor Regulation.

l 2.

I am duly authorized to participate in answering Interrogatories

  1. 74 to #76 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

l A

J, Subscribed and sworn to before me this t/ day of May,1982.

i'

/_ktb]s>

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Notary PubHc' My Comission expires: f/,g

UNITED STATES OF AhERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING'B_0ARD-In the Matter of

)I UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEliENT CORPORATION)

TENNESSEE VALLEY AUTHORITY

))

')

(ClinchRiverBreederReactor Plant)

AFFIDAVIT OF PAUL LEECH i

4 1 Paul Leech, being duly sworn, state as follows:

1 I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Project Manager, Clinch River Breeder Reactor Program Office, i

i f

Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatories 2.

  1. 70 through #73, #76 and #90 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

7

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PAUL LEECH Subscribed and sworn to before me this / fjf dty of May,1982.

4$ 10M

' Notary Publiu '-

My Comission expires:

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9 ss' UNITED STATES OF NtERICA 6

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-y?

In the Matter of

)I UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY

)

(Clinch River Breeder Reactor Plant) ))

AFFIDAVTT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

?

I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Project Manager, Clinch River Breeder Reactor Program Office, 8

Office of Nuclear Reactor Regulation.

I i

I am duly authorized to participate in answering Interrogatory #90 2.

of the 20th Set and I hereby certify that the answers given I

are true to the best of my knowledge.

1 du'

'r

, RICHARD M' 51 ARK Subscribed and sworn to before me r.

I this f d day of May,1982.

(ZO JA Notary Public,.,

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My Comission ek'pires: f[

l

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY IOMMISSION I

.?

l BEFORE THE ATOMIC SAFETY AND LICENSING BOAliD In the Matter of ll l

U.S. DEPARTMENT OF ENERGY l

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY l

l (ClinchRiverBreederReactorPlant)ll l

4 AFFIDAVIT OF JOHN K. LONG i

I I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a r

Nuclear Engineer, Research Systems Branch. Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1 through #45, #49, #53, f54, f63, #64, #65, #66, #67, #68, #69, f
  1. 77, #78, #82 and #83 of '.he 20th Set and I hereby certify that t

the answers given are true to the best of n knowledge.

i P

Y hw QMG

/

JOHN K.

LONG Subscr ed and siorn to before me this day of May,1982.

Nt i u, Y2f Notary Public My Comission expires:

14.1981 hfy Commi,% EMm Omic

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2 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tti!SSION'

[

~

BEFORE THE ATOMIC SAFETY AND LICENSING B0ARD i

lll In the Matter of UNITED STATES DEPARTMENT OF ENERGY h Docket No. 50-537 PROJECT !!ANAGEMENT CORPORATION l

TENNESSEE VALLEY AUTHORITY

)

I h)

(Clinch River Breeder Reactor Plant) 9 AFFIDAVIT OF MICHAEL KALTMAN 1, liichael Kaltman, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission.as a Regional Planning Analyst, Siting Analysis Branch, Division of Engineering, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 79, #80 and #81 of the 20th Set and I hereby certify that the answers given are true to the best of my knowledge.

)

Michael Kaltmin' Subscribed.and sworn to before me this daf',of May,1982.

/)bilf

'X1t W Notary PubtTc "

My Comission expires: ff

s-UNITED STATES OF MiERICA NUCLEAR REGULATORY COMMISSION,

s BEFORE THE ATOMIC SAFETY AND LICENSING 1 0ARD i

In the Matter of ll l

UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION J)

TENNESSEE VALLEY AUTHORITY (ClinchRiverBreederReactorPlant)

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

i 1.

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

Office of Nuclear Reactor Regulation.

i.

2.

I am duly authorized to participate in answering Interrogatories il l

through #12 of the 21st Set and I hereby certify that the answers given are true to the best of my knowledge.

l Carcis L. Allen Subscr bed and sworn to before me this y day of May,1982.

OL0h

$d Notary P@lic My Comission expires: 14[fA

UNITFn STATES OF AMERICA NUCLEAR REGULATORY COMMISSION,.

BE'F0D.E THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of

)

l l

UNITEDSTATESDEPARTMENTOFENERGYh Docket No. 50-537 PROJECT MANAGEliENT CORPORATION g

TENNESSEE VALLEY AUTHORITY

)

(ClinchRiverBreederReactorPlant))

1 AFFIDAVIT OF SHLOMO S. YANIV, Sc.D.

f' I, Shlomo S. Yaniv, being duly sworn, state as follows:

(

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Radiological and Health Effects Specialist. Health Effects Branch, Division of Health Siting, and Waste Management, Office of Nuclear Regulatory Research.

I am duly authorized to participate in answering Interrogatories #6, 2.

  1. 7, #8 and #9 of Section II of the 22nd Set and I hereby certify that the answers given are true to the best of my knowledge.

f w.

Shlomo S. Yaniv, Sc.D Subscripdandsworntobeforeme this f day of May, 1982.

2 0B O T F. Acirt,.w.

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NOTAIY FUEUC STATE OF //x;tte ;;

s 4,

i My Comminion Empires My 1,1922 J

r Notary Public My Comission expires: [

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION:

1-BdORETHEATOMICSAFETYANDLICENSINGBOARD y

l)l In the Matter of U.S. DEPARTMENT OF ENERGY lll Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY 1

(ClinchRiverBreederReactorPlant)lI l

AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch. Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories

  1. 1,#3, #12 of the 17th Set and I hereby certify that the answers given are true to the best of my knowledge.

O ALv m

JOHN K. LONG Subsc ed and-sworn to before me

\\

this.

day of/May,1982, i A U0 f

Notary Public My Comission expires:

7 Camin;oe EzPm October 14,19tj i

f UNITED STATES OF AW RICA 1

NUCLEAR REGULATORY COMMISSION

?

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _

l

'l}

)

')

In the Matter of

}h Docket No. 50-537 U.S. DEPARTitEfiT OF ENERGY

)

PROJECT MAtSGEMENT CORPORATIONl TENNESSEE VALLEY AUTHORITY 1

(ClinchRiverBreederReactorPlant)')

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows:

I am employed by the U.S. Nuclear Regulatory Comission as e 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

j I am duly authorized to participate in answering Interrogatories #4, 2.

  1. 8 through fil of the 17th Set and I hereby certify that the answers given are true to the best of my knowledge.

A T,ARDIS L. ALLEN Subscribed and sworn to before me this gday of,May,1982.

d$b' /

Notary Puolic (j

My Comission expires: 7h [A

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 10ARD 7

1 i

In the Matter of I

UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY

)

(ClinchRiverBreederReactorPlant))t AFFIDAVIT OF HOWARD B. HOLI I-1, Howard B. Holz, being duly sworn, state as follows:

i I am employed by the U.S. Nuclear Regulatory Comission as a 1.

Systems Engineer, Cifnch River Breeder Reactor Program Office, Office cf Nuclear Reactor Regulation.

i I am duly authorized to participate in answering Interrogatories il 2.

and #2 of the 18th Set and I hereby certify that the answers given are true to the best of my knowledge.

h Noward 5. Holz Subscribed and sworn to before me this y'#_ day of May,1982.

Al2hI/W.

d[

I

' Notary Public My Cor:inission expires: 7/'f[f7 w

=-y

1 I

3 UNITED STATES OF AMERICA

[,'

NUCLEAR REGULATORY COMMISSION,'

i BEFORE THE ATOMIC SAFETY AND LICENSING

  • BOARD

't r

In the Matter of ll I

UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENilESSEE VALLEY AUTHORITY h

l l

(Clinch River Breeder Reactor Plant) !l 1

AFFIDAVIT OF BILL M. MORRIS l

I, Bill M. Morris, being duly sworn, state as follows:

l 1.

I am employed by the U.S. Nuclear Regulatory Comission as a l

Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

i 2.

I an duly authorized to participate in answering Interrogatories il and #2 of the 18th Set and I hereby certify that the answers given s

ll are true to the best of my knowledge.

l!

1?

LE] M M9WpuA Bill M. Morris l

Subscribe and. sworn to before me this day.of May,1982.

l DjNJ.

N 2-Notary Public My Comission expires: g

f l

1

.i i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

BEFORE THE ATOMIC SAFETY AND LICENSING ~ BOARD I

i In the Matter of p

I UNITED STATES DEPARTMENT OF ENERGY ll Docket No. 50-537 PROJECT MANAGEMENT CORPORATION I

TENNESSEE VALLEY AUTHORITY l

(ClinchRiverBreederReactorPlant))I i

I AFFIDAVIT OF RICHARD M. STARK i

f i

I, Richard M. Stark, being duly sworn, state as follows:

i 1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, I

Office of Nuclear Reactor Regulation.

1 1

l' I am duly authorized to participate in answering Interrogatories il 2.

j and #2 of the 18th Set and I hereby certify that the answers'given are true to the best of my knowledge.

h h

f j

Rict.ard M. Stark Subscribed and sworn to before me this

/fday.of May, 1982.

/50bt Notary PublV L '

My Comission expires: f/f

UNITED STATES OF AMERICA J.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING 40ARD

?

~

In the Matter of p

l UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION I

i TENNESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor Plant) )I AFFIDAVIT OF CARDIS L. ALLEN i

I, Cardis L. Allen, being duly sworn, state as follows:

i 1.

I am employed by the U.S. Nuclear Regulatcry Comission as a I

Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 and #2 of the 18th Set and I hereby certify that the answers given are true to the best of my knowledge.

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Cardis L. Allen Subscribed and sworn to before me this day of May 1982.

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UNITED STATES OF MiRICA I

o NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARDA 3

In the Matter of ll UNITED STATES DEPARTMENT OF ENERGY l>)

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

)

)

TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) 0 j

AFFIDAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

lI I am employed by the U.S. Nuclear Regulatory Connission as a 1.

Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

J I am duly authorized to participate in answering Interrogatories 2.

  1. 2, #17 through #40, #48 and #49 of the 19th Set and I hereby certify that the answers given are true to the best of g knowledge.

l N.

d0ubs Richard Becke?

Subscr bed and sworn to before me this j ay of May, 1982.

AA Wotary PubTic g

My Commission expires: 7[//fA o

~

UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tt11SSION.

BEFORE THE AT0ft!C SAFETY AND LICENSINF280ARD

~.

In the Matter of

}I UNITED STATES DEPARTMENT OF ENERGY h Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

i TENNESSEE VALLEY AUTHORITY h

(Clinch River Breeder Reactor Plant) )I i

AFFIDAVIT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

I am duly authorized to participate in answering Interrogatory f50 2.

of the 1 % h Set and I hereby certify that the answers given i

are true to the best of my knowledge.

bt RICHARD fl. 5TARK (

Subscri ed and sworn to before me this, Znday of May,1982.

s/m 24 1

Notary Public.

My Comission ek ires: 7//

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l

~;.

UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION

-l BEFORE THE ATOMIC SAFETY AND LICENSINdB0ARD I

lll In the Matter of UNITED STATES DEPARTMENT OF ENERGY h

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h

TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) h>

AFFIDAVIT OF JOHN V. NEHEMIAS 1, 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 Interrogatories ill, #12, #15 and #16 of the 19th Set and I hereby certify that l

the answers given are ti-ue to the best of g knowledge.

((. dd_-h Q.n~V. Nehemias Subscribed and sworn to before me this g/j day of May,1982.

b/bj

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' Notary Pu5 Tic

/

liy Comission expires: 1/',,g

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tti!SSION I

m.

v BEFORE THE ATOMIC SAFETY AND LICENSING SOARD

'S l

In the Matter of l Jocket No. 50-537 UNITEDSTATESDEPARTMENTOFENERGYl PROJECT MANAGEMENT CORPORATION / TENNESSEE VALLEY AUTHORITY p 1 (Clinch River Breeder Reactor h i Plant) J I AFFIDAV110F MICHAEL KALTMAN i I, Michael Kaltman, being duly sworn, state as fdllows: e I am employed by the U.S. Nuclear Regulatory Comission as a 1. l Regional Planning Analyst, Siting Analysis Branch, Division of i Engineering, Office of Nuclear Reactor Regulation. f I am duly authorized to participate in answering Interrogatory #9 2. of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge. / Michael Kaltman Subscribed and sworn to before me this g day,o May ,1982. GYhlt (dnr i ' Notary Pnblic My Connission expires: 77, 7

i UNITED STATES OF'IMERICA NUCLEAR REGULATORY C0ltilSSION t ? BEFORE THE ATOMIC SAFETY AND LICENSING.B0ARD 1 In the Mr.tter of' ll l UNITED STATES DEPARTMEfiT OF ENERGY l} Docket No. 50-537 PROJECT MANAGEMENT CORPORATION 1 TENNESSEE VALLEY AUTHORITY l ')) (Clinch River Breeder Reactor Plant) AFFIDAVIT OF PAUL LEECH I, Paul Leech, being duly sworn, state as follows: i 1. I am employed by the U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. 2. I am duly authorized to participate in answering Interrogatories l

  1. 5, #6, #7, #50 of the 19th Set and I hereby certify that the answers given are true to the best of py knowledge.

? PAUL LEECH Subscri and sworn to before me. this _ day of May, 1982. Nf /v i Notary Public e My Comission e'xp' ires: '/// g l .~ ~

UNITED STATES OF: AMERICA NUCLEAR REGULATORY COMMISSION i ~ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i'-

)I In the Matter of U.S. DEPARTMENT OF ENERGY I

Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l TENNESSEE VALLEY AUTHORITY ll (ClinchRiverBreederReactorPlant)h) AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatories #2, 2.

  1. 17 through (40, #48, #49 of the 19th Set and I hereby certify that the answers given are true to the best of my knowledge.

.. /* CT.M0\\ JOHN K. LONG Subscri d and.tworn to before me this day of May. 1982. ENevl bd Notary Public My Comission expires: hty,Commhaion Expim Octobet 14,1981

y i UNITED STATES OF #1 ERICA 'v. NUCLEAR REGULATORY COMMISSIONS BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD i I l In the Matter of } >l { UNITED STATES DEPARTMENT OF ENERGY l l Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) l)l AFFIDAVIT OF PETER B. ERICKSON I, Peter B. Erickson, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a f Project Manager Standardization and Special Projects Branch, Division of Licensing Office of Nuclear Reactor Regulation. t' I am duly authorized to participate in answering Interrogatories #2 2. and #3 pertaining to Contention 14 (renumbered as 8) of the 10th Set and I hereby certify that the answers given are true to the best of my knowledge. 'l Peter B. Erickson Subscr bed and' sworn to before me this fjdayof.May, 1982. /I74l0 1/Hh y ' Nota ~rf PubTit g My Comission expires: 7g =

=

=

~ ~ UNITED STATES OF* AMERICA NUCLEAR REGULATORY COMMISSION i = ~ BEFORE THE ATOMIC SAFETY AND LICENSING'BOAND ?. 1 i 4 In the Matter of ll UNITED STATES DEPARTMENT OF ENERGY I Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h' TENNESSEE VALLEY AUTHORITY 1 (Clinch River Breeder Reactor Plant) ll l t AFFIDAVIT OF BILL M. MORRIS i I, Bill M. Morris, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Connission as a Section Leader of the Technical Review Section, Clinch River Greeder Reactor l i Program Office, Office of Nuclear Reactor Regulation. l 2. I am duly authorized to participate in answering Interrogatories il through #68 and #70 through #100 of the lith Set and I hereby certify that the answers given are true to the best of my knowledge. 4 ! h tW) awl Bill M. Morris Subscribed and sworn to before me this,.f7jf day of May, 1982.

  1. f24

/ g hotary PubHc My Cocnission expires: 7 M

.i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i BEFORE THE ATOMIC SAFETY AND LICENSING 10ARD N. In the Matter of ll I UNITED STATES DEPARTMENT OF ENERGY l Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h TENNESSEE VALLEY AUTHORITY J (Clinch River Breeder Reactor Plant) )) AFFIDAVIT OF JERRY J. SWIFT I, Jerry.J. Swift, being duly sworn, state as follows: l l I am employed by the U.S. Nuclear Regulatory Comission as a 1. l Reactor Engineer, Clinch River Breeder Reactor Program Office, I Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatory #69 2. of the lith Set and I hereby certify that the answers given are true to the best of my knowledge. O O i erryJ/ Swift f F Subscribed and sworn to before me this day of May,1982. .Y> lb-x n /. Notary Public. - My Comission expires: '/

i l t . g. .z UNITFn STATES OF AMERICA NUCLEAR REGULATORY COMMISSION. c ? c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i I In the Matter of l)l \\ UNITED STATES DEPARTMENT OF ENERGY I Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l i TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) ll l AFFIDAVIT OF EDWARD F. BRANAGAN, JR I, Edwaru F. Branagan, Jr., being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Radiological Physicist, bdiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. 2. I am duly authorized to participate in answering Interrogatories #6, through #I0 of Section III of the 12th Set and I hereby certify that the answers given are true to the best of sqy knowledge. l l l Edward F. Branagan, Jr. /v' Subscribed and sworn to before me thip 66 day of May,1982. /2 ? ( Kh A$Mi-4/ Notary Public' f i My Comission expires: 7[![4 1 1 l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION - 4 BEFORE THE ATOMIC SAFETY AND LICENSING SOARD In the Matter of ) l UNITEDSTATESDEPARTMENTOFENERGY) Docket No. 50-337 PROJECT MANAGEMENT CORPORATION /j TENNESSEE VALLEY AUTHORITY l (Clinch River Breeder Reactor Plant') AFFIDAVIT nF SHLOMO S. YANIV, Sc.D. I, Shlomo S. Yaniv, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Commission as a Radiological and Health Effects Specialist. Health Effects Branch, Division of Health Siting, and Waste Management Office of Nuclear Regulatory Research. (' l I an duly authorized to participate in answering Interrogatories in 2. Section I, il through #5, Section II, il through #39 and Section III, il through #5 of the 12th Set and I hereby certify that the answers I given are true to the best of,my knowledge. / 5hlomo 5. Yaniv, 5c.D. Subscribed and sworn to before me this 5% day 'of May,1982 ROBnf F. AISE', R. / /I NOTARY PUBUC STATE OF MMYLAND p( My Comminion Empires July 1,1982 j l My Comission expires: J INL 1

+ UNITED STATES OF AMERICA d i NUCLEARREGULATORYCOMMISSION{ 1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50 537 PROJECT MANAGEMENT CORFORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) AFFIDAVIT OF CILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River i Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. 2. I am duly authorized to participate in answering Interrogatories #1 through #54 of the 13th Set and I hereby certify that the answers given are true to the best of my knowledge. l l /d S An-f- BILL'M. MORRIS l Subscribed and sworn to before me this ' ay of by, 1982. J4%* C/OblXl hotary Public My Comission expires: 7 .=

~ UNITED STATES OF Af1 ERICA NUCLEAR REGULATORY COMMISSION 7 BEFORE THE ATOMIC SAFETY AND LICENSING BOXRD 2 In the Matter of ) ))) Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY Jl (Clinch River Breeder Reactor Plant) ') AFFIDAVIT OF BILL M. MORRIS f I, Bill M. Morris, being duly sworn, state as follows: i I am employed by the U.S. Nuclear Regulatory Comission as a Section 1. Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering #1 of Section IV #1 2. of the 14th Set and I hereby certify that the answers given are true to the best of my knowledge. t Y #1 #$w Bill M. Morris Subscribed and sworn to before me this gdayof May, 1982. O bM // ~ .~ hbtary PubMc g My Commission expires: I ' f'S O e a--- e%- w 'w w Tr ,v


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  • a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSISG B6ARD

.~ l In the Matter of' )I UNITED STATES DEPARTMENT OF ENERGYh Docket No. 50-537 l PROJECT MANAGEMENT CORPORATION i TENNESSEE VALLEY AUTHORITY h l I (ClinchRiverBreederReactorPlant)h AFFIDAVIT OF JERRY J. SWIFT _ i I, Jerry J. Swift, being duly sworn, state as follows: I am employed by the U.S. Nuclear Regulatory Comission as a 1. Reactor Engineer, Clinch River Breeder Reactor Program Office, l Of fice of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatories #3 2. f of Section II; #1 through f3 of Section V, il of Section VI and #1 of Section VII of the 14th Set and I hereby certify that the answers given are true to the best of my knowledge. 0/ br prryp.yswift' [ Subscribed and sworn to before me this M day of., May,1982. tLbi /1 M1 h~otary PubliT My Cor.nission expires: ((f((g l

UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN@ BOARD

  • t

? In the 11atter of ll> UNITED STATES DEPARTMENT OF ENERGY l Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h TENNESSEE VALLEY AUTHORITY 1 (ClinchRiverBreederReactorPlant))l l AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, being duly sworn, state as follows: t 1. I am employed by the U.S. Nuclear Regulatory Comission as a l Reactor Engineer, Clinch River Breeder Reactor Program Office, l i Office of Nuclear Reactor Regulation. ( 2. I am duly authorized to participate in answering Interrogatories fl - #4 of Section I, il and #2 of Section II, il and #2 of Section III, il of Section VIII and il through f5 of Section IX of the 14th Set and I hereby certify that the answers given are true to the best of my knowledge. A Cardis L. Allen Subscribed and sworn to before me this f-/j day of May,1982. AdWAn,, / Notary Pubac My Comission expires: 7/h

a ~ UNITED STATES OF NERICA NUCLEAR REGULATORY C0ffi!SSION ~; BEFORE THE ATOMIC SAFETY AND LICENSING ROARD In the Matter of ) ) UNITED STATES DEPARTMENT OF ENERGYI Docket No. 50-537 PROJECT MANAGEMENT CORPORATION h TENNESSEE VALLEY AUTHORITY h I (Clinch River Breeder Reactor Plant) h AFFIDAVITOFH6WARDB.HOLZ i I, Foward B. Holz, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Systems Engir.eer, Clinch River 3reeder Reactor Program Office. Office of Nuclear Reactor Regulation. 'l I am duly authorized to participate in answering Interrogatories il 2. through #6 of the 16th Set and I hereby certify that the answers given are true to the best of my knowledge. 1 y = HOWARD B. HOLZ l Subscribed and sworn to before me this y day of May, 1982. fllH]JD k l/ l Notary Public g My Comission exp' ires: -7/, I

z. UNITED STATES OF AMERICA s NUCLEAR REGULATORY COMMISSION 1 i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l > I In the Matter of i j U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION I TENNESSEE VALLEY AUTHORITY l (Clinch River Breeder Reactor Plant) i l AFFIDAVIT OF RICHARD BECKER J I I, Richard Becker, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, j Office of Nuclear Reactor Regulation. 2. I am duly authorized to participate in answering Interrogatories

  1. 1, #3, #12 of the 17th Set and I hert5y certify that the answers given are true to the best of my knowledge.

/&dBA RICHARD BECKER Subscrib d and sworn to before me thi e day of ",May,1982. A/AJ J Al%' Notary Pubhc ~ f/fh. My Comission expires: -= =

UNITED STATES Di AMERICA NUCLEAR REGULATORY COMMISSION h BEFORE THE ATOMIC SAFETY AND LICENS!N'G BOARD f In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 r PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) ,l AFFIDAVIT OF JOHN K. LONG I, John K. Long, being duly sworn, state as follows: I i f, 1. I am employed by the U.S. Nuclear Regulatory Comission as a Nuclear Engineer, Research Systems Branch. Office of Nuclear l Reactor Regulation. 2. I am duly authorized to participate in answering the Interrogatories in the 7th Set ar.d I hereby certify that the answers given are true to the best of my knowledge. f I.wnn JC N K. LONG Subscribed and sworn to before me this day of May ,1982. naai&& Notary Public My Comission expires: S!y Cemr.iulon Egira Ocobcr 14,198?

1 ~.. UNITED STATES OF AMERICA NUCLEAR REGULATORY OMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f-In the Ma'tter of-lt b l Docket No. 50-537 i UNITED STATES DEPARTMENT OF ENERGY t f PROJECT MAMAGEMENT CORPORATION

)

~ J TENNESSEE VALLEY AUTHORITY t (Clinch River Breeder Reactor )) Plant) i AFFIDAVIT OF CARDIS. L. ALLEN _ L. Allen, being duly sworn, state as follows: I, Cardis I am employed by the U.S. Nuclear Regulatory Comission as a 1. Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulaffon. I am duly authorized to participate in answering Interrogatories #1 2. through #4 of Section I of the 8th Set and I hereby certify that the I answers given are true to the best of my knowledge. 4 J'- y CARDIS L. ALLEN Subscribed and sworn to before me 198 2. this frf day of May.. l l6N/$1/wd Notary Publfc 1e((A My Comission expires: 4

q.. UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION ~, BEFORE THE ATOMIC SAFETY AND LICENSINS30ARD I. In the Matter of )) UNITED STATES DEPARTMENT OF ENERGY I Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l TENNESSEE VALLEY AUTHORITY ll (Clinch River Breeder Reactor Plant) )l AFFIDAVIT OF JERRY J. SWIFT i I, Jerry J. Swift, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatories il 9 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. h l]/ \\ M. b 6D Subscribed and sworn to before me this j day of May,1982. t//T}l1 $T1, ^ Notary Public l My Comission expires: 7/// p

=

UNITED STATES OF ERICA w NUCLEAR REGULATORY C0ffilSSION ~ BEFORETHEATOMICSAFETYANDLICENSINGBOAR6' F In the Matter of ) I UNITED STATES DEPARTMENT OF ENERGY h Docket No. 50-537 PROJECT MANAGEMENT CORPORATION 9 TENNESSEE VALLEY AUTHORITY ll l}I (Clinch River Breeder Reactor Plant) AFFIDAVIT OF ROBuRT J. DUBE I, Robert J. Dube, being duly sworn, state as follows: I am employed by the U.S. Nuclear Regulatory Con.(ssion as a 1. Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards. I am duly authorized to participate in answering Interrogatories 2. in Section IV, il through #5; Section V, il through f6; Section VI, il through #6; Section VII, il through #6; Section VIII, #1 and #2; Section IX, il and #2; and Section X, il and #2 of the 8th Set and I hereby certify that the answers given are true to the best of my knowledge. N.- ROBERT J. Dtf5E Subscribed and sworn to before me ROSFM F. ACBEY. JR. this 134 day of April, 1982. NOTARY PUEUC STATE CF MARYLANO fI h My Ccmmission hpires July 1,1982 (' g a notary vuosic T j ( ( 4 1't. ..s.. . t = =- = - =. . = - =

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, '] BEFORE THE ATOMIC SAFETY AND LICENSING. BOARD In the Matter of )I UNITED STATES DEPARTMENT OF ENERGY h 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 Comission as a Nuclear Engineer with the Accident Evaluation Branch, Division of Systems Integration Office of Nuclear Reactor Regulation. I 2. I am duly authorized to participate in answering Interrogatories 8(a) and 10 of the 9th Set of Interrogatories, and I hereby certify that the answers given are true to the best of my knowledge. 41/- e4 LARRY BELL SubscribeA.andsworntobeforeme this r,ioay of May, 1982. W Ms Kotary Public' My Comission expires: f// l

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING-BOAR'D ( In the Matter of p 1 I [ UNITED STATES DEPARTMENT OF ENERGYl l Docket No. 50-537 PROJECT 11ANAGEMENT CORPORATION I TENNESSEE VALLEY AUTHORITY ) l (Clinch River Breeder Reactor Plant) )) AFFIDAVIT OF JERRY J. SWIFT l I, Jerry J. Swift, being duly sworn, state as follows: ( 1. I am employed by the U'.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. ' l, l,' I am duly authorized to participate in answering Interrogatories 2.

  1. 8a and #10 of the Ninth Set and I hereby certify that the answers given are true to the best of my knowledge.

j 0 /7/ = Jer f.Swtft {* l Subscribed and sworn to before me this @ day of May, 1982. l/ bdh4 t Notary Pub)'tr,., My Comission expires: y pg

e-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING.50AR& In the Matter of ll ) UNITED STATES DEPARTMENT OF ENERGY ) Docket No. 50-537 I PROJECT MANAGEMENT CORPORATIONl l TENNESSEE VALLEY AUTHORITY (ClinchRiverBreederReactorPlant))> AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows: I am employed by the U.S. Nuclear Regulatory Comission as a Senior 1. Health Physicist, Radiological Assessment Branch Division of Systems Integration Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatories #1 2. and #2 of Section I; #1 and #2 of Section II and #1 through #8 of Section III of the 10th Set and I hereby certify that the answers i given are true to the best of my knowledge. f.N.$- M Ghn V. Nehemiar ~ Subscr bed and sworn to before me this $ day of May 1982. //rr //ldl /b Rotary Public My Comission expires: / g =

~ T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION. t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ll l U.S. DEPARTMEtiT OF ENERGY l Occket No. 50-537 PROJECT MANAGEMEllT CORPORATION ll TENNESSEE VALLEY AUTHORITY l (Clinch River Breeder Reactor Plant) h) AFFIDAVIT OF BILL M. MORRIS i i I, Bill M. Morris, being duly sworn, stite as follows: f 1. I an employed by the U.S. Nuclear Regulatory Comission as a Section Leader of the Technical Review Section, Clinch River 1 Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. 2. I am duly authorized to participate in answering Interrogatories il through #15 of Section I and #1 through #47 of Section 'I of the l 2nd Set and I hereby certify that the answers given are true to the best of my knowir Jge. c}} /r]. n%ts' BILL M. MORRIS Subscribed and sworn to before me thisgf/f, day of May,1982. af)[b n 1/m r, / Notary Public h Enemission eXDire0* / P1

~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION,' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i In the Matter of UNITED STATES DEPARTMENT OF ENERGY I Docket No. 50-537 PROJECT MANAGEMENT CORPORATION l TENNESSEE VALLEY AUTHORITY !l (Clinch River Breeder Reactor Plant) ) AFFIDAVIT OF HOWARD B. HOLZ t I, Howard B. Holz, being duly sworn, state as follows: 1. I am employed by the U.S. Nuclear Regulatory Cemission as a Systems Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. l 2. I am duly authorized to participate in answering Interrogatories il through #15 of Section I and #1 through f30 of Section II of the 3rd Set and I hereby certify that the answers given are true to the best of my knowledge.

f..,Yv$

Noward B. Holz / Subscribej and 3 worn to before me this //C day of May,1982. /!Ab UAM ' Notary PubTic My Commission expires: 7//((p 1

~ 9' UNITED STATES OF AMERICA f NUCLEAR REGULATORY COMMISSION.c l ~ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' \\ In the Matter of lI ) I Docket No. 50-537 UNITED STATES DEPARTriENT OF ENERGY l 4 PROJECT MANAGEtiENT CORPORATION l ) TENNESSEE VALLEY AUTHOU TY (Clinch River Breeder Reactor Plant) )) AFFIDAVIT OF BILL M. MORRIS

1. Bill M. Morris, being duly sworn, state as follows:

t' I am employed by the U.S. Nuclear Regulatory Comission as a Section 1. Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatories il 2. through #7 of Section I and il through #28 of the 4th Set and I hereby (~ certify that the answers given are true to the best of sty knowledge. d) A) && Bill M. tiorris Subscribed and sworn to before me l. this g day of May, 1982. fEl/YM tl w Rotary Public g My Comission expires: 7/f((p i ~ ~ - ' 'hp-e

e t i UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY C0t111SSION - 1 BEFORETHEATOMICSAFETYANDLICENSING' BOAR ( In the Matter of l} ) UNITED STATES DEPARTMENT OF ENERGYh Docket No. 50-537 PROJECT 11ANAGEt1ENT CORPORATION J TENNESSEE VALLEY AUTHORITY J )) (ClinchRiverBreederReactor Plant) AFFIDAVIT OF ROBERT J. DUBE I, Robert J. Dube, being duly sworn, state as follows: t I am employed by the U.S. Nuclear Regulatory Comission as a 1. Section Chief of Regulatory Activities and Analyses Section, Fuels Facilities Safeguards Licensing Branch, Division of Safe-guards, Office of Nuclear Material Safety and Safeguards. I am duly authorized to participate in answering Interrogatories 2. in Section III, #1 through #9 of the 6th Set and I hereby certify that the answers given are true to the best of my knowledge. l M ROBERT J. DUBE / ~ and sworn to before me Subscribegda of Apr 1,1982. l this U- ].hgf]g3Q,[..uyt,1982*[phr [i ( ,,[. '. ~ Notary Public g 71-My Comission expires: J l( 1

i UNITED STATES OF AMERICA e-NUCLEAR REGULATORY COMMISSION,- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ll )l Docket No. 50-537 UN]TED STATES DEPARTMENT OF ENERGY ' PROJECT MANAGEMENT CORPORATION l TENNESSEE VALLEY AUTHORITY h i (Clinch River Breeder Reactor Plant) ') AFFIDAVIT OF CHARLES L. MILLER i I, Charles L. Hiller, being duly sworn, state as follows: I am employed by the U.S. Nuclear Regulatory Comission as a l 1. Nuclear Engineer, Effluent Treatment Systems Branch, Division of Syttems Integration, Office of Nuclear Reactor Regulation. I am duly authorized to participate in answering Interrogatory #10 2. of the 1st Set and I hereby certify that the answers given are i true to the best of my knowledge. d w KIL l CHARLES L. MILLER Subscr bed and sworn to before me this / day of May ,1982. ~. l O// l/ m hotary Pubhr Hy Cornission expires: "7 f l W W

t i ~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, ./- BEFORE THE ATOMIC SAFETY AND LICENSING 80ARh ~ In the Matter of )) UNITED STATES DEPARTMENT OF ENERGYlll Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY h (ClinchRiverBreederReactorPlant))> AFFIDAVIT OF JOHN V. NEHEMIAS I, John V. Nehemias, being duly sworn, state as follows: t I am employed by the U.S. Nuclear Regulatory Comission as a 1. Senior Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation. l' I am duly authorized to participate in answering Interrogatory fil 2. of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge. han b k.1 Ae t Q n 7. Nehemias Subscribed and sworn to before me this f/dayof May, 1982. J/>-: A b) / Vn~ Notary Public 1 - My Cocynission expires: 7//[gg l l m -v -..,..-.._m._ m--

UNITED STATES OF AfiERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' l '{ In the Matter of ll ) UNITED STATES DEPARTMENT OF ENERGY h' Docket No. 50-537 i PROJECT MANAGEllENT CORPORATION h) li', TENNESSEE VALLEY AUTHORITY I (Clinch River Breeder Reactor Plant) ') t i ? AFFIDAVIT OF LARRY W. BELL f. i, I, Larry W. Bell, being duly sworn, state as follows: t li i-I am employed by the U.S. Nuclear Regulatory Comission as a 1. Nuclear Engineer, Accident Evaluation Branch, Division of Systems

lI Integration, Office of Nuclear Reactor Regulation.

'i i' I am duly authorized to participate in answering Interrogatory i 2.

  1. 9 of the 1st Set and I hereby certify that the answers given are true to the best of my knowledge.

l i u;a LARRY b. BELL i Subscrib and sworn to before me this day of May,198E. j (YL L 1-fiotary PublW - ~ 11y Comission expires: e l l

UNITEDSTATESOFhMERICA f NUCLEAR REGULATORY COMMISSION : } l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f l In the Matter of- 'l i l UNITEDSTATESDEPARTMENTOFENERGYl l Docket No. 50-537 l PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY lll l l (ClinchRiverBreederReactor l Plant) J AFFIDAVIT OF MICHAEL KALTMAN 1, Michael Kaltman, being duly sworn, state as follows: i 1. I am employed by the U.S. Nuclear Regulatory Comission as a Regional Planning Analyst, Siting Analysis Branch, Divisfon of Engineering, Office of Nuclear Reactor Regulation. l ll 2. I am responsible for providing the updated answers to the State of Tennessee Interrogatories, and I hereby certify that the updated i answers are true to the best of my knowledge. 1 I, 'h v ~ Micfhael Kaltman Subscribed and sworn to before me p g day of g 1982. i this , >niY bi-xw, Hotary Public My Comission expires: //[ .=

a.- f UNITED STATES OF AMERICA. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOhRD In the Matter of ) ) UNITED STATES DEPARTMENT OF ENERGY ) Docket No. 50-537 PROJECT MANAGEMENT CORPORATION ) TEUNESSEE VALLEY AUTHORITY ) ) (Clinch River Breeder Reactor Plant) ) h AFFIDAVIT OF MICHAEL BENDER I, flichael Bender, being duly sworn, state as follows: (NRC) I am employed by the U.S. Nuclear Regulatory Commission l. as a Consultant through a contract between the Clinch River 'I Breeder Reactor Program Office, NRC, and Brookhaven National i i Laboratories. i I am employed by the Brookhaven National Laboratories as a 2. Senior Scientist in the !!edical Department. I am duly authorized to participate in answering the March 18,19 3. Ninth Request for Admissions pertaining to Contention 8b kenumber-l l &O O e

.2-s 41throughi12andIherebychr'tifythattheanswersgiven as 11) are true to the best of my knowledge. ,= fh y-MICHAEL BENDER Subscribed and sworn to before me this 6 day of May, 1982. G.*R ALDtNF CALLISTER , s ),. $ fa fl t'.$$e's 5 SeY 452 0542945 mec. m ss= m.ean,mes I Notary Public W 4o, IT ES My com:nission expires: l 4 e o "e* e +, _,. a ^ - ~ - - - -}}