ML20054B771
| ML20054B771 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/15/1982 |
| From: | Bradley Jones, Nizuno G, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8204190183 | |
| Download: ML20054B771 (47) | |
Text
i April 15, 1982 UNITED STATES OF AMERICA m
NUCLEAR REGULATORY COMMISSION T
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PROJECT MANAGEMENT CORPORATI0fl
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TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor
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NRC STAFF FIRST ROUND OF DISCOVERY TO NRDC, ET AL.
In accordance with the Board's February 11, 1982 Prehearing Conference Order, the NRC hereby submits to Intervenor Natural Resources Defense Council, Inc. and the Sierra Club (NRDC, et al., or NRDC) its first round of discovery on the "old contentions" in this proceeding.
This discovery consists of interrogatories, requests for admissions, and requests for documents. These categories of discovery are set out separately below.
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INTERROGATORIES Pursuant to 10 C.F.R. 5 2.740(b) and the Board's February 11, 1982 Prehearing Conference Order, the NRC Staff requests NRDC, et al. to respond to the following interrogatories in writing and under oath by l
April 30, 1982.
For each interrogatory, provide the following answer, in accordance with the terms of the parties' March 4,1982 " Protocol For Di scovery":
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a)
Provide the direct answer to the question.
b)
Identify all documents and studies, and the particular parts thereof, relied upon by NRDC, now or in the past, which serve as the basis for the answer.
In lieu thereof, at NRDC's option, a copy of such document and study may be attached to the answer.
c)
Identify principal docunents and studies, and the particular parts thereof, specifically examined but not cited in (b).
In lieu thereof, at NRDC's option, a copy of each such document and study may be attached to the answer.
d)
Identify by name, title and affiliation the primary NRDC employee (s) or consultant (s) who provided the answer to the question, indicating the qualifications of that person to answer the question.
e)
Explain whether NRDC, et al. are presently engaged in or intend to engage in any further, on-going research program which may affect its answer. Failure to provide such an answer means that NRDC, et al. do 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 NRDC, et al.
intend 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 NRDC et al.
have in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to the Staff.
NRDC Contention 1 (formerly NRDC 2) 1-1.a.
What level of confidence does NRDC contend is adequate for deter-mining that shut-down systems are reliable?
b.
Specify your basis for selecting the confidence level specified in response to a. ahnve.
O.
1-2.a.
- 1) Define " scientifically validated procedure" as used by NRDC in its response to Interrogatory 2 of " Natural Resources Defense Council, et al. Response to Applicants' Interrogatories Dated November 18, 1975," dated December 9, 1975, in this proceeding.
2)
Provide a list of what NRDC contends to be " scientifically validated procedures" for determining the reliability of CRBR
)
shut-down systems. Describe the source of these procedures, and i
your bases for conluding that these procedures are scientifically validated.
b.
Specify your bases for the answer to 2.a. indicating what acceptance criterie, nethodology, data and tests you consider j
necessary and sufficient to establish that a procedure for determining reliability of CRBR shut-down systems is "scienti-fically validated."
l 1-3.
Specify each aspect of the Applicant's " reliability program" that you contend is inadequate, or which contributes to the inability of the " reliability program," even if implemented, to eliminate CDAs as DBAs.
1-4 What level of experience, within the meaning of your response number 2(a) under Contention 2(b) of your January 13, 1977
" Admissions by Natural Resources Defense Council to Applicants' Request (First Setl" (Admissions) does NRDC contend is suffi-ciently extensive, with respect to the development of reliability l
data for instrumentation and electronic equipment similar to i
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that used in the CRBR shutdown and shutdown heat removal systems, to permit that data to be a useful predictor of the reliability j
of the similar CRBR equipment.
1-5.
Provide the reason (s) why you contend that CDAs should be included within the envelope of DBAs.
1-6.
Considering the fact that the Staff requires that the CRBR accommodate CDAs, explain quantitatively how requiring CDAs j
to be included within the DBA envelope, (i.e. requiring the CRBR to be designed to withstand CDA's) as you contend should i
be done, would enhance public safety.
1-7.a.
Define what you would accept as a "sufficiently low" probability i
to allow CDAs to be excluded from the envelope of DBAs.
b.
Provide the bases and justification for your response to part
- a. above.
j 1-8.
Describe the transients you believe must be classified as anticipated transients within the meaning of your Contention I
1(a).
l.
1-9.a.
Describe in detail the "other CDA initators" that you believe must be evaluated to determine if their probabilities of occurrence are low enough to allow them to be excluded from the envelope of DBM.
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b.
Provide the bases and justification from your response to question a. above.
1-10.
Define what you would view as " reliable data" required for the analysis described in Contention 1.(a).
)
1-11.a.
Regarding Contention 1 b(1), identify the portions of the PSAR, by section and page number, that identify analyses which con-stitute the bases for the first sentence of this subcontention.
I b.
Specify what amount of failure mode data NRDC contends would be sufficient "to validly employ these techniques in predicting i
the probability of CDAs."
c.
Identify the " techniques" referenced in this subsection.
d.
What failure mode data do you believe would be pertinent to the CRBR system?
e.
How do you contend that failure mode should be applied to predictions of probabilities of CDAs?
f.
Explain how you would determine if the Applicants can " validly employ these techniques in predicting the probability of CDAs."
1-12.
Regarding Contention 1 b)(2):
a.
Identify the projected data base referenced in the first sentence of this subcontention.
b.
Specify the basis for NRDC's contention that Applicants must establish that the projected data base must encompass all credible failure modes and human elements.
In responding
1 to this interrogatory, define what "all credible failure modes and human elements" means in this subcontention.
c.
Specify those credible failure modes and human elements which NRDC contends are lacking from Applicants' projected data base to be used in the reliability program.
1-13.
Regarding Contention 1 b)(3):
a.
Specify what NRDC contends the "sufficiently low probability" must be for the occurrence of a CDA at CRBR in order to exclude the CDA from the CRBR design basis.
b.
Specify your bases for selecting the probability identified in response to a above, indicating what acceptance criteria, methodologies, data, and tests you rely on in support of these bases.
c.
Assuming the data base is etablished as postulated in the subcontention, what do you contend precludes establishing that CDAs have a sufficiently low probability as defined i
above?
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1-14.
Regarding Contention 1 b)(4):
Indicate your basis for asserting that Applicants must complete the test program used for their reliability program prior to their projected date for completion of construction of the CRBR.
1-15.a.
Identify the page number and, if appropriate, section of the documents specified in your "New Information Relevant to Intervenors' Contentions", attached to the fiarch 12, 1982 letter to Staff and Applicants' counsel from NRDC counsel, at pages 2 and 3, relating to former Contention 2, now Contention 1, upon i
which you intend tn rely in supporting a position regarding Contention 1 in this proceeding.
b.
Specify which subpart of Contention 1 each reference in response to a. above relates, and in each case indicate how you contend that the reference supports that subcontention.
1-16.
Explain what you mean by " established" in this part of your contention, i.e., what degree of demonstration do you believe is required to " establish" that the Applicants' test program will be completed prior to its projected construction comple-tion date?
NRDC Contention 2 (formerly NRDC Contention 3) 2-1.
Describe the specific areas of the Applicants' and Staff's analyses of CDAs and their consequences which you believe are inadequate for purposes of licensing the CRBR.
2-2.
Describe the specific areas of the Applicants' and Staff's analyses of CDAs and their consequences which you believe are inadequate for purposes of performing the flEPA cost / benefit analysis for the CRBR.
j 2-3.
Explain the distinction, if any, you make in this contention between the CDA analysis required for purposes of licensing the CRBR and for purposes of performing the NEPA cost / benefit analysis for the CRBR.
2-4.
Since the radiological source term required by 10 C.F.R.
i j
100.11(a), fn.1 applies only to accidents considered credible i
(i.e., DBAs), explain why you contend that CDA analyses must be adequate to demonstrate that the potential hazards from CDA will not exceed those associated with the 10 C.F.R. 100.11(a) l fn.2 source term.
2-5.a.
In your response to Request number 1 under (old) Contention 3(a) of your January 13, 1977 admissions to Applicants' first set of requests for admissions, you state that the Applicants' analyses of CDAs do not include the most significant CRBR HCDA scenarious, nor that they are valid or conservative."
Indicate what NRDC contends to be the most significant valid CDA scenarios and consequences for CRBR for purposes of licensing the CRBR, per-forming the NEPA cost / benefit analysis, or demonstrating that the radiological source term for the CRBR would result in potential hazards not exceeded by those from any accident considered credible, b.
Specify the basis for selecting the response to a. above, indi-e cating what criteria, methodology, data, and tests you consider necessary to determine the most significant valid CDA scenarios from the CRBR.
_g.
2-6.a.
Does NRDC contend that Applicants and Staff must analyze all CDA scenarios and their consequences for purposes of licensing the CRBR, performing the NEPA cost / benefit analysis, or demon-strating that the radiological source term for the CRBR would result in potential hazards not exceeded by those from any accident considered credible?
b.
If the answer to a. above is yes, specify the basis, including supporting data upon which NRDC relies, for so concluding.
c.
If the answer to a. is no, indicate what NRDC contends the criteria should be for determining what CDAs and their conse-quences should be analyzed; specify your basis for selecting the criteria.
2-7.a.
Indicate what bases NRDC relies upon for contending that the radiological source term analysis for CRBR site suitability should be determined through a mechanistic analysis.
Specify applicable regulations, criteria, guidance, and other factors which NRDC relies upon for support for its bases, b.
Explain what NRDC means by a " mechanistic analysis" in this conter, tion.
c.
Define the characteristics of a mechanistic analysis that you contend an acceptable for the purpose of this contention.
2-8.
Indicate what bases NRDC relies upon for contending that an accident analysis should be performed as indicated in Conten-tion 2.b).
Specify in the bases applicable regulations, criteria, guidance, and other factors which NRDC contends support this part of Contention 2.
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2-9.
Regarding Contention 2.b):
a.
What does NRDC contend in the first part of this contention which is different from what is contended in new Contention 1 and the first part of subpart (a) to new Contention I?
b.
Define what NRDC means by " explosive potential" in 2.b).
c.
Describe the methodology by which a " conservative estimate of the fission product release from [CDA]" could be performed that you contend would be adequate; specify the aspects of this methodology.
d.
Explain why the reference in 2.b) to fission product release from CDAs is not subsumed in the first part of 2.c).
2-10.
Regarding Contention 2.c):
a.
Specify the releases of fission products and core materials which NRDC contends are inadequately considered in the Applicants' radiological source term analysis.
Include in this specification your bases for contending that these releases are inadequately considered.
b.
Specify the fission product releases and core material releases which NRDC contends should be considered in the radiological source term analysis.
c.
Specify che environmental conditions which NRDC contends are inadequately considered in the Applicants' radiological source term analysis.
Include your bases for contending that these conditions are inadequately considered.
d.
Specify the environmental conditions which NRDC contends should be considered in the radiological source term analysis.
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e.
Specify (1) what NRDC contends should be the maximum credible sodium release following a CDA and (2) the environmental conditions caused by such a sodium release for determining the radiological source term pathway analysis.
f.
Specify the bases for the response to e. above, indicating the criteria, methodology, data, and other factors upon which you rely in specifying the release and environmental conditions.
2-12.
Regarding Contention 2.d):
a.
What methodology does NRDC contend should be utilized, what tests must be performed, and what is the minimum amount of data necessary, to demonstrate that the design of the containment of CRBR is adequate to reduce calculated offsite doses to an acceptable level? In responding, define what you include in your meaning of " design of the containment."
b.
Specify the bases for selecting the methodology, tests, and data indicated above.
c.
Does NRDC contend that it is impossible to design a containment for the CRBR which is adequate to reduce calculated offsite doses to an acceptable level?
d.
If the answer to c. above is yes, specify the bases upon which you rely to arrive at that conclusion.
e.
If the answer to c. above is no, specify the containment designs that you are aware of which you contend would be adequate to reduce offsite doses to an acceptable level; indicate the specifics of the CRBR containment design which differ materially from these acceptable designs.
f.
Does NRDC contend that the CRBR containment design is inadequate to reduce calculated offsite doses to an acceptable level?
g.
If the answer to f. above is yes, specify the bases for this conclusion, indicating the specific aspects of the CRBR containment design which you contend are inadequate.
h.
Define what the offsite doses you contend are acceptable.
Provide the bases upon which you rely for your response to the extent that these doses differ from NRC regulatory requirements.
Please be specific.
2-13.
Regard Contention 2.f):
a.
Specify the aspects of those computer models (including computer codes) used by the Applicants and the Staff for the CRBR which NRDC currently contends are invalid within the meaning of Contention 2.f).
b.
Specify the bases upon which you rely to conclude that the models and codes set forth in response to a. above are invalid.
c.
Identify the methodology, tests, data, and other factors which NRDC contends must be utilized in order to demonstrate
that the computer models and codes referenced in Conten-tion 2.f) are adequately validated, verified, and documented.
d.
Does NRDC contend that any of the computer models and codes referenced in the Applicants' or the Staff's CDA analysis accurately represent the physical phenomena and principles which control the response of the CRBR to CDAs? If so, specify which models and codes are valid.
e.
Specify the physical phenomena and principles, within the meaning of your Contention 2.f), which you contend control the response of CRBR to CDAs.
f.
What criteria do you contend must be utilized to provide assurance that computer models accurately represent the physicai phenomena and principles which control the response of CRBR to CDAs?
h.
In the context of subcontention 2.f), define what you mean I
by:
1) adequately documented 1
2) adequately verified 3) adequately validated i.
If you distinguish between verified and validated, explain this difference.
J.
What is meant by " applicable experimental data?"
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. 2-14.
Regarding Contention 2.g):
a.
What methodology, tests, data, or other factors do you contend should be utilized to establish that the input data and assumptions for the computer models and codes are adequately documented or verified within the meaning of your Contention 2.g)?
b.
What are the specific bases upon which you rely in arriving at the factors specified in response to a. above?
c.
Describe in detail any and all " input data for the computer models and codes" that you contend are not adequately docu-mented and, in a separate list, those that are not adequately verified.
d.
Describe in detail any and all " assumptions for the computer models and codes" which you contend are not adequately documented and, in a separate list, those that are not adequately verified.
2-15.
Regarding Contention 2.h):
a.
Explain in detail what you contend to be the relationship between establishing the energetics of the CDA and the containment of the source term for post accident radio-l logical analysis.
b.
Define what you mean by post accident radiological analysis.
c.
Does subcontention 2.h) represent NRDC's summation of its i
conclusions set forth in Contention 2.a) through 2.g)?
. d.
If the answer to c. above is yes, does 2.h) rely solely on the conclusions set forth in 2.a) through 2.g)?
e.
If the answer to c. or d. above is no, set forth the specific conclusions or argunents upon which you rely in support of your conclusion in 2.h).
f.
Does your Contention 2.h) rely solely on the bases that you have asserted for Contention 2.a) through g) which you have set forth in response to interrogatories 2-1 through 2-14 above?
g.
If the answer to c. above is no, specify what other factors, including the bases for each factor, upon which you rely in support of your conclusion in Contention 2.h), to the extent not provided in response to c. above.
Regarding Contention 3 (formerly NRDC Contention 4) 3-1.
Regarding Contention 3.a):
a.
Identify with specificity those accident possibilities which you contend are of greater frequency or consequence that the accident scenarios analyzed by the Applicants and Staff, within the meaning of your Contention 3.a).
b.
For each accident scenario identified in response to a.
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above, provide the specific bases upon which you rely l
I to support your conclusion as to the frequency or con-sequence of that accident, indicating what that frequency and consequence is, c.
To the extent not included in your specific listing provided in response to a. above, list and describe those specific accident scenarios not analyzed by the Applicants
or the Staff which you contend must be analyzed as part of the CRBR review.
d.
The Staff notes that you have taken the position that methodology similar to that used in the Rasmussen Report must be utilized to analyze accident possibilities.
(NRDC et al. Response of December 9,1975 to Applicants' Inter-rogatories of November 18, 1975, number 4(c)).
Identify acceptance criteria, empirical data, tests, research, or other factors besides methodology such as frequency which you contend must be utilized in conjunction with the Rasmussen-type methodology to identify the required CRBR accident possibilities, (i.e. those accident possibilities which you contend must be considered).
e.
Identify the bases upon which you rely to contend that the criteria, data, tests, research, or other factors identi-fied in response to d. above are appropriate and necessary l
to identify CRBR accident possibilities.
f.
Define what you mean by " sufficient attention."
3-2.
Regarding Contention 3.b):
a.
What acceptance criteria does NRDC contend must be satisfied in determining whether Applicants' and Staff's analyses of potential accident initiators, sequences, and events are sufficiently comprehensive to assure that analysis of the DBAs will envelop the entire spectrum of l
credible accident initiators, sequences, and events?
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b.
Specify the bases which NRDC contends support the acceptance criteria set forth in response to a. above.
c.
Specify the potential accident initiators, sequences, and events which you contend were not adequately considered, or were not considered, by the Applicants or Staff and which you contend should be factored into the analysis of DBAs for the CRBR to assure that DBAs are adequately analyzed.
d.
Provide the specific bases upon which NRDC relies to support its contention that the factors specified in response to c.
above must be included in the DBA analysis, e.
As used by you in this subcontention, define:
1) credible accident initiators 2) credible sequences 3) credible events 4) the entire spectrum 3-3.
Regarding Contention 3.c):
a.
Identify those accidents addressed by Contention 3.c) which you contend are inadequately analyzed, identifying the specific aspects of the accidents which have not been adequately analyzed, and specifying which aspects deal with core meltthrough and which with sodium-concrete interactions.
b.
Indicate the specific bases upon which you rely to support your conclusion that the aspects of the accidents identi-fied in response to a. above are inadequately analyzed.
I
c.
Specify the acceptance criteria, data, tests, or other factors which you cotend must be utilized to assure that core meltthrough accidents are adequately analyzed.
d.
Identify the specific bases upon which you rely to contend that the acceptance criteria, data, tests, or other factors identified in response to c. above are appropriate and necessary to assure that the accidents are adequately analyzed.
e.
Explain whether or not you contend that a core meltthrough necessarily occurs following a loss of core geonetry; provide your reasons supporting this conclusion, f.
Define what you mean by loss of core geometry in this subcontention.
3-4.
Regarding Contention 3.d):
a.
Specify the methods by which you contend human error can initiate, exacerbate, or interfere with the mitigation of CRBR accidents. The examples must be carried far enough to clearly demonstrate how the consequences would be significantly worse had the human error not occurred.
b.
Provide the bases upon which you rely to support your answer to a. above.
NRDC Contention 5 (formerly NRDC 6)
The following interrogatories relate to NRDC Contention 5(a).
5(a)-1.a. Define the term, "less favorable", as that term is used in Contention 5(e.)(1).
- b. What criteria does NRDC utilize in determining whether site meteorology is "less favorable"? What are the bases for NRDC's selection of these criteria?
J 5(a)-2.a. Are there meteorological parameters or factors, other than wind speed and inversion conditions, that NRDC believes must be uti-lized in evaluating site meteorology?
- b. If so, list and describe these parameters, and provide the bases for selection of these parameters. Rank the parameters in order of importance in the evaluation of site meteorology.
- c. List and describe the criteria NRDC utilizes in ranking the parameters.
5(a)-3.a. What are the bases for NRDC's contention that sites other than Clinch River have more favorable wind speed and inversion condi-tions?
- b. List, and provide supporting documentation, for all sites which NRDC claims have more favorable wind speed and inversion condi-tions, compared with the CRBR site.
5(a)-4.
List, and provide supporting documentation, for sites which NRDC claims in Contention 5(a)(2) have more favorable meteorological characteristics, compared with the CRBR site.
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5(a)-5.
List, and describe with particularly the meteorological dis-advantages of the CRBR site.
Provide the bases for NRDC's response.
5(a)-6.
Define the term, " population density", as that term is used in Contention 5(a)(2).
State the methodology for calculation of population density, as this term is defined by NRDC.
5(a)-7.a. Define the term, "less favorable", as that term is used in Contention 5(a)(2).
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- b. What criteria does NRDC utilize in determining whether population density is "less favorable". What are the bases for NRDC's selection of these criteria?
5(a)-8.
List, and provide supporting documentation, for all sites which NRDC believes have more favorable population densities l
than the CRBR site.
5(a)-9.a. Define the term, " population characteristics", as that term is used in Contention 5(a)(3).
- b. List all " population characteristics" which NRDC believes are relevant in assessing site suitability for a breeder reactor.
- c. Does NRDC contend that there are disadvantageous population characteristics, other than population density, associated with the CRBR site?
If so, please list, describe and provide
f' the bases for all disadvantageous population characteristics associated with the CRBR site.
5(a)-10.a. Does NRDC contend that the analysis of alternative sites meteorology and population density contained in the Staff Final Environmental Statement ("FES") is inadequate, and/or gave insufficient weight to these factors?
- b. If so, please list, describe, and provide the bases for all NRDC-perceived inadequacies in the FES.
5(a)-11.a. Define the term, " insufficient weight", as that term is used in Contention 5(a).
- b. What are the criteria or parameters which NRDC contends should be used in determining the " weight" to be given to meteorological and population factors? What are the bases for NRDC's response?
- c. Does NRDC contend that meteorology is a major or overriding factor in identifying suitable sites for a breeder reactor?
If so, state the reasons for this conclusion and provide the 1
l bases for the resoonse.
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- d. What numerical weight should be assigned to meteorology as a l
l criterion in evaluating alternative sites for the CRBR? How l
does NRDC derive this numerical weight?
- e. Does NRDC contend that population characteristics are a major or overriding factor in identifying suitable sites for a l
. breeder reactor? If so, state the reasons for this conclusion and provide the bases for the response,
- f. What numerical weight should be assigned to population characteristics as a criterion in evaluating alternative sites for the CRBR? What methodology does NRDC use to derive this numerical weight?
The following interrogatories relate to Contention 5(b).
5(b)-1.
Please list all " proposed energy fuel cycle facilities"
(" facilities") in "close proximity" to the CRBR which NRDC claims may result in " unacceptable risk" to national security and the national energy supply if there was a "long-term evacuation" of those facilities due to an accident at CRBR.
5(b)-2.
Define "close proximity" to the CRBR site. State the maximum radial distance from the CRBR plant itself that NRDC contends would constitute "close proximity".
5(b)-3.
Does NRDC contend that the distance which constitutes "close proxinity" to CRBR is fixed? If not, list and describe all variables that may affect the distance which constitutes "close proximity".
l 5(b)-4.
What are the criteria for determining the distance from the CRBR plant which NRDC contends constitutes "close proximity"?
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5(b)-5.
Define " evacuation", as that term is used in Contention 5(b).
5(b)-6.
Does " evacuation" include a partial shutdown of the facilities identified in Interrogatory 5(b)-1? If so, please specify the percentage decrease in the operating level of those facilities which NRDC contends will constitute " evacuation".
If a percen-tage cannot be specified, so state, and give reasons for this position.
If NRDC feels that other criteria or parameters are more appropriate to measure the degree of shutdown of a facility, identify those criteria or parameters and the basis for relying on those criteria.
5(b)-7.
State the minimum period of time which NRDC contends constitutes a "long-term" evacuation. What is NRDC's basis for specifying this time period.
If NRDC cannot state a minimum time period, what criteria or parameters does NRDC contend should be taken into account in determining the time period which constitutes a "long-term" evacuation.
5(b)-8.
Specify with particularity the accidents or accident conse-quences at CRBR which NRDC contends may result in long-term evacuation of the facilities identified in Interrogatory 5(b)-1.
5(b)-9.
Specify with particularity the (1) national security; a$d (2) national energy supply " risks" which NRDC contends are unacceptable if an accident at CRBR caused a long-term evacu-1 m
ation of the facilities identified in Interrogatory 5(b)-1.
This list should be inclusive of every national security and national energy supply risk which NRDC contends are raised by a possible accident at CRBR.
5(b)-10.
Define " unacceptable", as that term is used in Contention 5(b).
5(b)-11. Specify the criteria which NRDC contends must be used in determining whether a risk is " unacceptable".
5(b)-12.
Dose NRDC contend that an identified risk to national security or the national energy supply is per se an unacceptable risk, regardless of the probability of its occurrence?
Cor.tention 6 (formerly NRDC 9) 6-1.
Define the term " environmental impact" as it is used in Contention 6.
i 6-2.
Define the tern " fuel cycle" as it is used in Contention 6.
6-3.
List each type of facility in the "12e1 cycle" in which "the ER and FES do not include an adequate analysis."
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6-4.
For each facility listed in response to question 6-3, provide the basis (i.e., methodology of analysis, and any documents used in that analysis) for your statement that the "the ER
and FES do not include an adequate anaysis of the environmental impact" for that particular facility.
6-5.
What is the source (i.e., radiation and/or chemicals) of the environmental impact referred to in Contention 6.
Contention 6(b)(1) 6-6.a.
Define the term " impact" as it is used in Contention 6(b)(1).
Specify the individuals or groups that will be subject to this impact.
b.
List the types of impacts of reprocessing of spent fuel and plutonium separation that are "not included" in the ER.
c.
List the types of impacts of reprocessing of spent fuel and plutonium separation that are "not included" in the FES.
d.
List the types of impacts of reprocessing of spent fuel and I
plutonium separation that are " inadequately assessed" in the FES.
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e.
List the types of impacts of reprocessing of spent fuel and plutonium separation that are " inadequately assessed in the ER.
NRDC Contention 7 (formerly NRDC 10) 7-1 Assuming no technical difficulties in implementing the program, explain fully what factors NRDC believes would result in the CRBR program not fulfilling the objectives of the LMFBR Program on a timely basis.
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Note: The above question is aimed at factors NRDC perceives will prevent the CRRR from meeting the programmatic objectives of the LMFRB program even if the CRBR program advanced to completion without any technical difficulties.
NRDC Contention 7(c) (formerly NRDC 10(g) 7(c)-1 List all environmental and safety characteristics which NRDC contends must be utilized in assessing the suitability of alternate sites for CRBR.
7(c)-2(a) State the numerical "weicht" which NRDC contends should be given to the environmental and safety characteristics identified in Interrogatory 7(c)-1.
(b) What criteria does NRDC contend should be utilized in determining j
the numerical " weight" to be given to each of the environmental and safety characteristics identified in Interrogatory 7(c)-1?
7(c)-3(a) List and describe all " site selection criteria" which NRDC believes should be used in identifying alternative sites.
Are these criteria the same as the environmental and safety l
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characteristics identified by NRDC in response to Interrogatory 7(c)-1?
(b) What is the basis for selecting the " site selection criteria" identified in response to Interrogatory 7(c)-3(a)?
7(c)-4 In addition to the specific alternative sites (i.e., Hanford Reservation, Nevada Test Site) which are identified by NRDC are there other sites which NRDC contends must be evaluated?
If so, please list these sites and provide the basis for NRDC's contention that these sites may offer "substantially better" characteristics.
7(c)-5 State the reasons why an underground site is more favorable from an environmental and safety point of view, considering that the Applicants' current design for CRBR includes double containment.
l 7(c)-6 Identify the party that NRDC contends is responsible for assessing alternative sites.
If NRDC is of the belief that either Applicants or Staff may assess alternative sites, so state.
(
NRDC Contention 8 (formerly NRDC 14) 8-1 List and described the adverse environmental effects associated with the decommissioning of CRBR which NRDC contends are l
unavoidable.
Provide the basis for NRDC's contention that these adverse environmental effects will be associated with the decommissioning of CRBR.
8-2 Provide the basis for NRDC's assertion that the adverse environmental effects identified by NRDC in response to Interrogatory 8-2 are " unavoidable".
8-3 State precisely what NRDC contends the Applicants must do in order to " adequately analyze" the unavoidable environmental effects associated with the decommissioning of CRBR.
8-4 State precisely what NRDC contends the NRC Staff must do in order to " adequately analyze" the unavoidable environmental effects associated with the decommissioning of CRBR.
8-5 Identify with particularity the basis, legal or otherwise, l
for NRDC's contention that the Applicants and/or Staff must analyze " unavoidable" environmental effects associated with the decommissioning of CRBR.
8-6 Define the term, " internalized economic costs", as that term is used in Contention 8.
8-7 List and describe all " internalized economic costs" associated with the decommissioned CRBR which NRDC believes have not been
" adequately assessed" in the CRBR NEPA review.
Provide the basis for NRDC's belief that these internalized costs will be associated with a decommissioned CRBR.
8-8 Define the term, " external social costs", as that term is used in Contention 8.
8-9 List and describe all " external social costs" associated with the decommissioned CRBR which NRDC believes have not been
" adequately assessed" in the CRBR NEPA review.
8-10 Does NRDC contend that the Applicants must assess economic and social costs of decommissioning as part of the NEPA review of CRBR?
8-11 Does NRDC contend that the Staff must assess economic and social costs of decommissioning as part of the NEPA review of CRBR?
8-12a.
Describe with particularity what NRDC believes are the inadequacies of the assessment of the economic and social costs of the decomrissioned CRBR.
b.
Describe with particularity what NRDC believes the parties must do to " adequately analyze" the enconomic and social cost of the decommissioned CRBR.
8-13 Describe with particularity the inadequacies of the analysis i
of decommissioning in the Applicants' Environmental Report ("ER").
8-14 Identify and describe with particularity what NRDC believes are the inadequacies of the analysis of decommissioning in the NRC Staff's Final Environmental Statement ("FES").
i 8-15 Identify and describe with particularity all "ommissions" in environmental impact statements ("EIS") for Light Water Reactors (" LWR's"), as alleged by NRDC in Contention 8(b).
8-16 Identify those sections of the CRBR FES which contain onmis-sions analogous to the omissions which NRDC identifies and describes in the response to Interrogatory 8-13.
8-17 Is NRDC aware of any revised, supplementary, or superseding report or study to the Harwood report? If so, provide NRC Staff with a copy of such document.
8-18 Does NRDC believe that Ni-59 will be present in quantities equal to that of Ni-63, or in quantities equal to one percent i
of Ni-63? Provide the basis for NRDC's response.
8-19 List all neutron activation products which NRDC believes will be produced by CRBR. Provide the bases for NRDC's response.
8-20 Define the term, " systematically analyze", as this term is used in Contention 8(d).
4 8-21 Describe with particularity what NRDC believes the NRC Staff must do to " systematically analyze" all neutron activation products produced by CRBR.
8-22 For the neutron activation products identified by NRDC in response to Interrogatory 8-19, identify those that NRDC contends the NRC Staff must " systematically analyze".
8-23a.
Define the term, " potential isolation period", as this term is used in Contention 8(d).
b.
List and describe with particularity all acceptable methods of computing or otherwise estimating this period.
l 8-24 Describe with particularity the process or method by which the potential isolation period will be factored (taken into account) into the analysis of economic and social cost associated with decommissioning. Provide the bases for NRDC's response.
NRDC Contention 11 (formerly NRDC 8) i l
11-1.
Define the term " health consequences" as it is used in Contention 11.
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- t 11-2.
Define the term " safety consequences" as it is used in Contention 11.
11-3.
Specify the " current NRC standards for radiation protection of the public health and safety" that are referred to in Conten-tion 11 by citation to specific NRC regulations or rules.
11-4.
What types of radiation from CRBR (alpha, beta, camma or neutron) do you contend "have not been adequately analyzed by Applicants" in Contention 11?
11-5.
What types of radiation from CRBR (alpha, beta, gamma or neutron) do you contend "have not been adequately analyzed by... Staff" in Contention 11?
11-6.
Specify the types of radioactive effluents from CRBR (i.e.,
I airborne effluents, and/or liquid effluents) that are the sources of the exposures to radiation that you contend "have not been adequately analyzed by Applicants" in Contention 11.
11-7.
Specify the types of radioactive effluents from CRBR (i.e.,
airborne effluents, and/or liquid effluents) that are the sources of the exposures to radiation that you contend "have not been adequately analyzed by... Staff" in Contention 11.
\\
11-8.
For each type of radioactive effluent identified in response to questions 6 and 7, provide the bases (i.e., methodology of analysis, and any documents used in that analysis) for your statement that the particular type of radioactive effluent from CRBR has "not been adequately analyzed by Applicants or Staff."
11-9.
For each type of radiation from CRBR (i.e., alpha, beta, gamma or neutron) identified in responses to question 4 and 5, identify the particular radionuclides that NRDC contends "have not been adequately analyzed by Applicants or Staff."
11-10.
Define the term "public" as it is used in Contention 11.
11-11.
Define the term " plant employees" as it is used in Contention 11.
11-12.
For each radionuclide identified in response to question 11-9, j
provide the basis (i.e., methodology of analysis, and any documents used in that analysis) for your statement that the i
particular radionuclide has "not been adequately analyzed by Applicants or Staff."
Contention 11(a) 11-13.a.
Define the term " exposures" as it is used in Contention 11(a).
b.
What are "public and plant employees" exposed to as the term
" exposures" is used in Contention 11(a)?
I.
c.
Define "as low as practicable (reasonably achievable)" as it is used in Contention 11(a).
d.
What are the bases for your contention that the release of radioactive material from the CRBR are not ALARA? Provide the analysis that was used in your ALARA determinations.
Contention 11(b) 11-14.a.
Define the term " genetic effects" as it is used in Contention 11(b).
j b.
Specify the parts of the body that might be exposed as the term
" exposure" is used in Contention 11(b).
1 c.
For each part of the body that is identified in response to b.
above, identify the types of radiation that you are concerned with in your contention that:
neither Applicants nor Staff have adequately assessed the genetic effects from radiation exposure."
d.
Where do you postulate the individuals will be located who will be exposed to radiation as the term " radiation exposure" is used in Contention 11(b).
Contention 11(c) 11-15.a.
Define the term " exposure" as it is used in Contention 11(c).
b.
What are " plant employees and the public" exposed to as the term " exposure" is used in Contention 11(c).
c.
Specify the parts of the body that might be exposed as the term " exposure" is used in Contention 11(c).
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e d.
Identify the particular radionuclides for which you contend
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"neither Applicant or Staff have adequately assessed the induction of cancer from the exposure of... the public."
Contention 11(d) 11-16.a.
Specify the " guideline value for permissible organ doses" that are referred to in Contention 11(d).
b.
Define " permissible organ doses" as it is used in Contention 11(d).
c.
Provide the bases that support your contention that the guide-line values... have not been shown to have a valid basis.
Contention 11(d)(1) 11-17.a.
Define " organ dose equivalent limits" as it is used in Contention 11 (d)(1).
b.
List all of the "important organs" that are referred to in Contention 11(d)(1).
c.
For each "important organ" listed in response to Contention 11(d)(1), state why that particular organ is important in l
" establishing 10 C.F.R. 100.11 organ dose equivalent limits."
d.
Identify by page number and paragraph number "the recommenda-tions of the ICRP in Report 26" that are referred to in Contention 11 (d)(1),
e.
Identify by page number and paragraph number "the recommenda-tions of the ICRP in Report..
30" that are referred to in Contention 11(d)(1).
f.
Define the term "new knowledge" as it is used in Conten-tion 11(d)(1).
g.
Provide a date to distinguish oetween "new knowledge" and "old knowledge."
h.
List the references, (other than ICRP 26 and 30) incibding page and paragraph numbers, that NRDC considers "new knowledge."
Contention 11(d)(2) 11-18.a.
Define the term " adequate" as it is used in Contention 11 (d)(1).
b.
Define the term " plutonium ' hot particle' hypothesis" as it is used in Contention 11(d)(2).
c.
Provide the most recent references to the " plutonium ' hot particle' hypothesis advanced by Arthur R. Tamplin and Thomas B. Cochran."
d.
Provide the most recent references to the " plutonium ' hot particle' hypothesis advanced by... Karl Z. Morgan."
e.
Identify the parts of the human body in which "neither Applicant or Staff have given adequate consideration of the plutonium
' hot particle' hypothesis."
f.
For each part of the human body listed in response to e. above, provide the bases (i.e., methodology of analysis, and any documents (include page numbers and paragraph numbers) used in that analysis) for your statement that "neither Applicant or Staff have given adequate consideration to the plutonium
' hot particle' hypothesis" for that particular body organ.
l
. Interrogatories Related to Requests For Admissions The following interrogatories relates to the Staff's requests for admissions which immediately follow these interrogatories.
I 1.
For each statement identified in the following requests for 3 ';
admissions which you deny, provide the following information:
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a.) The portion of statement which is not admitted.
b.) The basis of your disagreement with the statement.
c.) The expert witnesses, if any you are relying on in disagreeing with the statement.
d.) The document, if any, you are relying on in disagreeing with the statement.
~
e.) The articles, if any, you are rr'"ina on in disagreeing with the statement.
2.
Regarding requests for admissions numbers 1 'and under s
Contentions 4 and 6, provide the following additional information:
If NRDC does not admit to Admissions 1 or 2 -(or both) below, s
state specifically what factors about the design or' siting of CRBR make it impossible or impracticable to protect against the design basis threats in 10 C.F.R. 7J.1(a)(1) and (2).
3.
If NRDC does not admit (or objects to) Admission 1 related to Contention 7, following these interrogatories, state specifically every alternative design which NRDC telives must-be -
considered for CRBR.
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REQUEST FOR ADMISSIONS Pursuant to 10 C.F.R. 5 2.742, the NRC Staff requests admissions by NRDC et al. of the following matters of fact:
Regarding Contentions 4 and 6 i
1.
From a factual (as opposed to legal) standpoint, there is nothing about the CRBR design or site which would make it techni: ally
]
impossible to have a safeguards and security system adequate to protect against the design basis threats in 10 C.F.R. 73.1 (a)(1) and(2).
i 2.
From a factual (as opposed to legal) standpoint, there is nothing about the CRBR design or site which would make it technically impracticable to have a safeguards and security system adequate to protect against the design basis threats in 10 C.F.R. 73.1(a)(1) and(2).
3.
Assuming a design basis act comparable to the threats described in 10 C.F.R. 73.1(a)(1) and (2) occurs, there is nothing about the CRBR design which would make it significantly moie difficult to defend against that act then an LWR at the same site.
4.
Assuming a design basis act comparable to the threats described in 10 C.F.R. 73.1(a)(1) and (2) occurs, there is nothing about the CRBR site which makes it particularly difficult to defend the site against that act.
5.
The environmental impacts, excluding dollar costs, from safeguards -
during the CRBR fuel cycle will not be significantly different from the environmental impacts from safeguards during the fuel cycle for an LWR, assuming the reprocessing and recycling of fuel in both fuel cycles.
6.
The environmental inpacts during the CRBR fuel cycle (excluding waste disposal) will not be significantly different from the environmental impacts from the fuel cycle (excluding waste disposal) for an LWR fuel cycle, assuming the reprocessing and recycling of fuel in both fuel cycles.
7.
The environmental impacts from waste disposal for the CRBR fuel cycle, although the content of the waste may be different, will not result in environmental impacts significantly different from impacts for the waste from the LWR fuel cycle for any waste dispcsal plan which has been proposed for nuclear waste products, assuming the reprocessing and recycling of fuel in both fuel cycles.
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Regarding Contention 7 1.
In addition to the technical matters raised in admitted Contentions, other then new Contention 7, the only alternative designs NRDC i
believes must be considered for CRBR which NRDC believes have not i
i yet been adequately considered are:
I a)
Fly wheels on the sodium pumps b) a core catcher i
c) the parfait core 2.
If the CRBR is built and operates as presently planned, without f
any technical difficulties (excluding the question of timeliness),
i the project will meet the objectives of the LMFBR Program.
3.
If the CRBR is built and operates as presently planned, without any technical difficulties, it will meet the LMFBR program objectives in a timely manner.
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4.
It is not necessary from a factual (as opposed to legal) stand-point to consider evary alternative design feature used at foreign breeders to design a breeder reactor which will meet the programatic objectives of the LMFBR Program.
Regarding NRDC Contention 11 b)-d):
The following admissions contemplate normal operation of the CRBR, l
including expected operational occurrences.
-. _ ~.
. 1 1.
The annual dose to the whole body of an individual from exposure to natural background radiation (i.e., cosmic e
radiation, terrestrial radiation, and internal sources) in the state of Tennessee is about 0.1 rem.
2.
The annual dose to the whole body of an individual from exposure to natural background radiation (i.e., cosmic 4
radiation, terrestrial radiation, and internal sources) in the U.S. varies from about 0.1 rem to about 0.3 rem, depending on location.
3.
The National Academy of Sciences, BEIR III Report estimates that the whole body dose to the population within 10 miles of commercial nuclear power plants exposed to radioactive effluents releases is much less than 0.01 rem /yr.
i 4
The quantities of airborne radiciodines and particulates that are likely to be released from CRBR are less than the quantities released from operating LWRs.
5.
The total quantities of liquid and gaseous radioactive effluents (Ci/yr.) for the CRBR are likely to be smaller than those for most operating LWRs.
l 6.
It is most likely that there will be no measurable transuranic elements released from the CRBR via the gaseous pathway during normal operation.
l 1
i 7.
The annual doses to the total body and each body organ of offsite individuals potentially exposed to routine releases of airborne radioactive effluents during normal operation from CRBR will be less than the corresponding doses form most operating LWRs.
8.
The annual doses to the total body and each body organ of offsite individuals potentially exposed to routine releases of radioactive liquid effluents from CRBR will be less than the corresponding annual doses from exposure to natural back-ground radiation in the state of Tennessee.
]
9.
The annual doses to the total body and each body organ of offsite individuals potentially exposed to routine releases i
of radioactive noble gases from CRRR will be less than the corresponding annual doses from exposure to natural background radiation in the state of Tennessee.
i
- 10. The annual doses to the total body and each body organ of offsite individuals potentially exposed to routine releases j
of airborne radioactive iodines and particulate effluents l
from CRBR will be less than the corresponding annual doses from exposure to natural background radiation in the state l
of Tennessee.
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- 11. Neither the National Academy of Sciences BEIR III Committee.
the National Council of Radiation Protection and Measurements, or the International Committee on Radiological Protection has endorsed "the plutonium ' hot particle' hypothesis" referenced in NRDC Contention 11.d)(2).
- 12. No authoritative radiation protection organization in the world with expertise in the area of potential health effects from ionizing radiation has endorsed "the plutonium ' hot particle' hypothesis."
- 13. During normal operation of CRBR, the maximally exposed individ-ual in the general public exposed to radioactive noble gases 1
in the plume from the CRBR would be situated at the CRBR site boundary.
- 14. The meteorological dispersion factor at the nearest CRBR site i
boundary for exposure to continuous releases during normal l
operation of the CRBR would be about 10-4 sec/m or less.
3 I
- 15. The nearest site boundary for CRBR would be about 0.4 miles from the facility.
- 16. During normal operation of the CRBR, the average dose to the population within 50 miles of CRBR exposed to airborne radio-active effluents would be less than the 10 C.F.R. 50 Appendix I dose design objectives for the maximally exposed individual by about two orders of magnitude or more.
REQUEST FOR DOCUMENTS Pursuant to 10 C.F.R. 5 2.741, the Staff requests NRDC et al. to produce the following documents:
1.
Letter, dated January 27, 1982, from Richard Shikiar, Director, Social Change Study Center, to Dr. Thomas Cochran, NRDC, referenced at page 3, section c.,
of "New Information Relevant to Intervenors' Contentions". The "New Information..." docu-ment was attached to a letter dated March 12, 1982 from counsel to NRDC to counsel to the NRC Staff and Applicants.
2.
The report by S. Harwood, May, K., Reshikoff, M., Schlenger, B.,
and Tames, P., entitled, " Decommissioning Nuclear Reactors" referenced in Contention 8.c).
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______m Respectfully submitted,
/
Y W niel T. Swanson Counsel for NRC Staff AD A!W 1
Bradley W. Jones Counsel for NRC Staff
, = ^m G ry
.f 'izuno r NRC Staf(r C n 1 Dated at Bethesda, Maryland this 15th day of April, 1982 i
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I UNITED STATES OF AMERICA e
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the flatter of UNITED STATES DEPARTMENT OF ENERGY
)
Docket No. 50-537 PROJECT MANAGEMENT CORPORATION
)
TENNESSEE VALLEY AUTHORIlf (Clinch River Breeder Reactor Plant)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF FIRST ROUND OF DISCOVERY TO NRDC, fit ET AL."
in the above-captioned proceeding have been served on the following by deposi the United States mail, first class, or as indicated by (*) through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by (**) hand delivery, this 15th day of April, 1982:
Marshall Miller, Esq., Chairman William M. Leech, Jr., Attorney General Administrative Judge William B. Hubbard, Chief Deputy Atomic Safety and Licensing Board Attorney General U.S. Nuclear Regulatory Commission Lee Breckenridge, Assistant Attorney Washington, D.C.
20555
- General 450 James Robertson Parkway Mr. Gustave A. Linenberger Nashville, Tennessee 37219 Administrative Judge Atomic Safety and Licensing Board Oak Ridge Public Library U.S. Nuclear Regulatory Commission Civic Center Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Dr. Cadet H. Hand, Jr., Director William E. Lantrip, Esq.
Administrative Judge City Attorney Bodega Marine Laboratory Municipal Building University of California P.O. Box 1 P.O. Box 247 Oak Ridge, Tennessee 37830 Bodega Bay, California 94923 Lawson McGhee Public Library Alan Rosenthal, Esq., Chainnan 500 West Church Street Atomic Safety and Licensing Appeal Knoxville, Tennessee 37902 Board Panel U.S. Nuclear Regulatory Commission Warren E. Bergholz, Jr.
Leon Silverstrom Washington, D.C.
20555 U.S. Department of Energy Dr. John H. Buck 1000 Independence Ave., S.W.
Atomic Safety and Licensing Appeal Room 6-B-256 Board Panel Washington, D.C.
20585 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
George L. Edgar, Esq.
Mr. Joe H. Walker Frank K. Peterson, Esq.
401 Roane Street Gregg A. Day, Esq.
Harriman, Tennessee 37830 Thomas A. Schmutz, Esq.
Irvin A. Shapell, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, D.C.
20036 Project Management Corporation P.O. Box U Oak Ridge, Tennessee 37830 Ellyn R. Weiss **
Dr. Thomas B. Cochran Barbara A. Finamore
'S. Jacob Scherr Natural Resources Defense Council, Inc.
1725 Eye Street, N.W., Suite 600 Washington, D.C.
20006 Mr. Godwin Williams, Jr.
Manager of Power Tennessee Valley Authority 819 Power Building Chattanooga, Tennessee 37401 Mr. Lochlin W. Coffey, Director Clinch River Breeder Reactor Plant Project U.S. Department of Energy Washington, D.C.
20585 Eldon V.C. Greenberg Tuttle & Taylor 1901 L Street, N.W., Suite 805 Washington, D.C.
20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Boaro U.S. Nuclear Regulatory Conmission Washington, D.C.
20555 Docketing and Service Section Q h Office of the Secretary laniel T. Swanson U.S. Nuclear Regulatory Cornission Counsel for NRC Staff Washington, D.C.
2055'S