ML20072U018
| ML20072U018 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/07/1983 |
| From: | Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club |
| To: | JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| References | |
| NUDOCS 8304110134 | |
| Download: ML20072U018 (6) | |
Text
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'83 APR -7 P 3:12 April 7, 1983 lic$h5h$d6:
fi?AhCH UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.-
Dr. Cadet H. Hand, Jr.
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In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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~ 50-537 i
PROJECT MANAGEMENT CORPORATION
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Docket No.
TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
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NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND THE SIERRA CLUB'S FIRST SET-OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUEST TO PRODUCE TO APPLICANTS i
Pursuant to 10 CFR $ 2.740b, and in accordance with the Board's Construction Permit Scheduling Order of_ March 29, 1983, Intervenors, Natural Resources. Defense Council, Inc. and the Sierra Club, submit the following interrogatories, to be answered fully, in writing and under oath, by one or more officers or
-employees of Applicants who has personal knowledge thereof or is the closest to having personal knowledge thereof.
If the interrogatories are answered by more than one person,.whether or r'JO4110134' B30407 5"" ^" '" i id
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L 2-not he or she verified the answers, and whether or not he or she is an officer or employee of Applicants, such person's name and
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title should be set forth together with'an identification of
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which interrogatories.he or she is responsible for.
Unless otherwise indicated, each question is addressed to all Applicants.
In each question to all Applicants, each of the l
multiple Applicants is instructed to provide a separate answer.
However, when all. Applicants are in agreement on a response, only l
one uniform answer need be given.
l-Each' answer to an interrogatory shall be preceded by a copy i
of the particular question to which the answer is responding.
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Each question is instructed to be answered in six parts, as I
i follows.
Answer to Question (a) Provide the direct answer to the question.
(b) Identify all documents and studies, and the particular i
parts thereof, relied upon by Applicants, now or in the f
past, which serve as the basis for the answer.
In lieu t
I thereof, at Applicants' option, a copy of such document and study may be attached to the answer.
(c) Identify ~ principal documents e.nd studies, and the 4
particular parts thereof, specifically examined by not i
cited in (b).
In lieu thereof, at Applicants' option, a.
copy of each such document and study may-be attached to I
the' answer.
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8~ -(d) Identify by name, title and affiliation the primary Applicants employee (s) or consultant (s) Who provided the 1
answer to the question.
(e) Explain Whether Applicants are presently engaged ~in or i
intend to engage in any further, ongoing research-l program which may affect Applicants' answer.
This.
answer need by provided only in cases where Applicants intend to rely upon ongoing research not included in j
Section 1.5 of the PSAR at the construction permit f
hearing on the CRBR.
Failure to provide such an answer means that Applicants does not intend to rely upon the existence of any such research at the LWA or construction permit hearings on the CRBR.
i (f) Identify the expert (s)i if any,.Which Applicants 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 i
j a group of related questions.
This answer need not be-provided until Applicants have in fact identified the expert (s) in question or determined'that no expert will testify, as long as such answer provides reasonable 1
. notice to Intervenors.
As used herein, " documents" include, but'are not limited to papers, photographs, criteria, standards of review, recordings,-
memoranda, books, records, writings, letters, telegrams,
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i mailgrams, correspondence, notes and minutes of meetings or of j
conversations or of phone calls, interoffice, intra-agency or i
j interagency memoranda or written communications of any-nature, 1.
j recordings of conversations either in writing or upon any
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mechanical or electronic or electrical recording devices, notes,.
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exhibits, appraisals, work papers, reports,. studies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, i
i drawings, manuals, notebooks, worksheets, contracts, agreements, j
letter agreements, diaries, desk calendars, charts, schedules, i
1 appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether-formal t
l or informal) of any of the foregoing, and also all copies of any i
I of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) from the original.
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l INTERROGATORIES l
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1.
Identify and describe in detail all analyses, statements j
and conclusions contained in Appendix A (and Attachments) of the a
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1, SER with which you are in disagreement.
The response to this
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interrogatory must inclu$e a detailed description or explanation i
of all bases for Applicants' disagreement.
As-to each'such analysis, statement or conclusion, j
a.
describe in detail all analyses performed by Applicants which support Applicants'. position.
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b.
Identify and provide any documents Which support the i
bases for Applicants' disagreement.
2.
Describe in detail the methodology Which Applicants j
believe should be used in developing a bone dose value for.
evacuation Protective Action Guides (PAG).
a..
Describe in detail any analyses, calculations or i
studies performed by Applicants in developing a bone dose j
PAG.
b.
Identify and provide all documents used by Applicants-in responding to this interrogatory.
3.
Identify and provide all documents,' exclusive of CRBRP-1, j
-2, and -3, the PSAR, and studies that clearly have.no bearing on
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the question of Whether the CDA should be a DBA, Which contains a.
CRBR probabilistic risk analyses, statements and l
conclusions; b.
quantitative fault tree analyses performed on.CRBR and its principal safety systems; l
c.
event tree analyses performed on CRBR and its j
principal safety systems:
1 d.
failure mode analyses performed on CRBR and its principal safety systems; 1
e.
common mode failure analyses performed on CRBR and its principal safety systems.
Respectfully submitted,
'!% ~ A.,k = -
Barbara A. Finamore S. Jacob Scherr Natural Resources Defense Council, Inc.
1725 I Street, NW, #600 Washington, D.C.
20006 (202) 223-8210 k
Ellyn R. Weiss HARMON & WEISS 1725 I Street, NW,#506 Washington, D.C.
20006 (202) 833-9070 Attorneys for Natural Resources Defense Council, Inc., and j
the Sierra Club Dated:
April 7, 1983 a
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