ML20054M599

Forwards Signed & Notarized Affidavits of Individuals Who Participated in Answering NRC Responses to NRDC & Sierra Club Tenth Request for Admissions & twenty-fifth Set of Interrogatories

ML20054M599
Person / Time
Site:	Clinch River
Issue date:	07/09/1982
From:	Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Finamore B, Weiss E National Resources Defense Council
References
NUDOCS 8207140025
Download: ML20054M599 (16)

Text

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DISTRIBUTION:

DTSwanson' BWJones GSMizuno MFSweeney July 9, 1982 SATreby MKarman Murray Barbara A. Finamore Christenbury/Scinto Ellyn R. Weiss ELD FF (2)

Natural Resources Defense Council, Inc.

Affi ants 1725 Eye Street, N.W., Suite 600 PLeech Washington, D. C.

20006 RStark CThomas DMB_PDR/LPDR In the Matter of Chron UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

Docket No. 50 537

Dear Ms. Finamore and Ms. Weiss:

Enclosed are copies of the signed and notarized affidavits of the NRC Staff who participated in answering "NRC Staff's Answers to NRDC, Inc. and the Sierra Club Tenth Request to Staff for Admissions" and "NRC Staff's Answers to NRDC, Inc. and the Sierra Club 25th Set of Interrogatories to Staff" filed on June 18, 1982.

Sincerely, Daniel T. Swanson Counsel for NRC Staff

Enclosures:

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY LOMilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor P'; ant)

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AFFIDAVIT OF JERRY J. SWIFT 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.

2.

I am duly authorized to participate in answering #1, #14 and #47 of the 10th Set of Request for Admissions filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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erry wift Subscribed and sworn to before me this 26 day of June, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY LOMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

)

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

1.

I an 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 Interrogatory #15 of the 10th Set of Request for Admissions filed on June 4,1982 and I hereby certify that the answers given are true to the best of my knowledge.

Ms htbm/k hilf Richard M. Stark Subscribed and sworn to before me this fs day ofd. g, 1982.

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

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TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

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o 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 Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering #2 through #11,

1. 13, #16 through 33 of the 10th Set of Request for Admissions filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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Bill M. Morris Sulscribed and sworn to before me this a day of g, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSINr. BOARD in the Matter of 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)

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o AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

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

1.

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

2.

I am duly authorized to participate in answering #39 through

1. 48 of the 10th Set of Request for Admissions filed on June 4, 1982 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 9 day of h.c\\%,1982.

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UNITED STATES OF M1 ERICA NUCLEAR REGULATORY t.0MMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

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

1.

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

2.

I am duly authorized to participate in answering Interrogatories #87 and #90 of the ?Eth Set filed on June 4, 1982, and I hereby certify that the answers given are true to the best of my knowledge.

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\\JotnV.Nehemias Subscribed and sworn to before me this A4 day of June,1982.

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UNITED STATES OF fMERICA NUCLEAR REGULATORY COPNISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) o AFFIDAVIT OF PAUL H. LEECH 4

I, Paul H. Leech, 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.

2.

I am duly authorized to participate in answering Interrogatory #68

1. 69 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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Paul H. Leech Subscribed and sworn to before me this

.2,4 day of June, 1982.

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Notary Pbblic My Comission expires:

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UNITED STATES OF fMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICELSING BOARD In the Matter of

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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)

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

1.

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

2.

I am duly authorized to participate in answering Interrogatories

1. 2, #8, #13 through #24, #31 through #34 and #91 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are tru'e to the best of my knowledge.

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Joh K. Long Subscribed and sworn to before me this day of June, 1982.

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Notary PQblic My Coninission expires:

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P UNITED STATES OF /NERICA NUCLEAR REGULATORY LOMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMEllT CORPORATION TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

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

1.

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

2.

I am duly authorized to participate in answering Interrogatories

1. 67 and #91 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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Richard Becker Subscribed and sworn to before me

'd day of June,1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY LOMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT HAhAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

AFFIDAVIT OF JERRY J. SWIFT 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.

2.

I am duly authorized to participate in answering Interrogatories 3, 5, 9, 10, 11, 28, 29, 30, 35, 47 and 82 of the 25th Set filed on June 4, 1982, and I hereby certify that the answers given are true to the best of my knowledge.

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Subscr_ibsd and sworn to before me this M day of June, 1982.

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UNITED STATES OF /MERICA NUCLEAR REGULATORY LOMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF M0HAN C. THADANI I, Mohan C. Thadani, being duly sworn, state as follows:

1.

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

2.

I am duly autrorized to participate in answering Interrogatory

1. 45 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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/4 Mohan C. Thadani Subscribed and sworn to before me thi ggd day f June, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY LOMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

AFFIDAVIT OF LARRY W. BELL I, Larry W. Bell, being duly sworn, state as follows:

1.

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

2.

I am duly authorized to participate in answering Interrogatories

1. 56, #57, #76 and #77 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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/g/f day of June, 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY J0PfilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

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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 Conunission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatory 1 of the 25th Set filed on June 4, 1982, and I hereby certify that the answers given are true to the best of my knowledge.

( ff Richard M. Stark Subscribed and sworn to before me this P, day of,ltme,1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY t.0MMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

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

2.

I am duly authorized to participate in answering Interrogatories

1. 4, #6, #7, #12, #58 and #67 of the 25th Set filed on June 4, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

Y k kfw Bill M. Morris Subscribed and sworn to before me this &

day of-June,1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY t,0MMISSION BEFORE THE AT0tlIC SAFETY AtlD LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

)

TENNESSEE VALLEY AUTHORITY

)

)

(Clinch River Breeder Reactor Plant)

)

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

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

1.

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

2.

I am duly authorized to participate in answering #79, #80, #84 through #86 and

1. 88 of the 25th Set of Interrogatories filed on June 4, 1982 and I hereby certity that the answers given are true to the best of my knowledge.

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Edward F. Branafan, Jr.

Subscribed and sworp to before me this day of-M %

,1982.

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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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UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

)

AFFIDAVIT OF CARDIS L. ALLEN I, Cardis L. Allen, 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.

2.

I am duly authorized to participate in answering Interrogatories 25 and 46 of the 25th Set filed on June 4,1982, and I hereby certify that the answers given are true to the best of my knowledge.

4.:1L L Cardis L. Allen Subscribed and sworn to before me this WWfay of July,1982, h%NW d\\M Notary Public 21 g D-My commission expires:

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