ML20065J764

Second Set of Admissions & Seventh Set of Interrogatories, Per ASLB 820831 Scheduling Order.Certificate of Svc Encl

ML20065J764
Person / Time
Site:	Clinch River
Issue date:	10/04/1982
From:	Bergholz W, Edgar G EDGAR, G.L., ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP.
To:	National Resources Defense Council, Sierra Club
References
NUDOCS 8210060200
Download: ML20065J764 (6)

Text

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10/4/82 00LKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W DCT -4 P4 54 0FFICE OF SECRETAh f In the Matter of ) DOCKETlHG & SE8 VIN

) BRANCH UNITED STATES DEPARTMENT OF ENERGY )

)

PR0h,CT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

APPLICANTS' SECOND SET OF ADMISSIONS AND SEVENTH SET OF INTERROGATORIES TO INTERVENORS' NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB Pursuant to 10 C.F.R. 5 2.742 and S 2.740(b), and in accordance with the Board's Scheduling Order of August 31, 1982, the United States Department of Energy and Project Management Corporation, for themselves and on behalf of the Tennessee Valley Authority, submit the following admissions and interrogatories to Intervenors, Natural Resources Defense Council, Inc., and the Sierra Club. NRDC is requested to admit or deny the truth of the matter asserted in each admission, answer each interrogatory, and submit responses within 14 days in writing and under oath, by one or more representatives of NRDC or the Sierra Club who have personal knowledge of the matters stated therein. Each answer to an admission or inter-rogatory shall be preceded by a copy of the particular admission to which the answer is responding.

C9210060200 821004 PDR ADDCK 05000537 i' ud.. PDR .

[

ADMISSIONS

1. NUREG-0625 has not been adopted by the Nuclear Regulatory Commission as nuclear reactor siting requirements in regard to site isolation and population density.

2. At this time the Nuclear Regulatory Commission's siting requirements in regard to site isolation and population density are set forth in a) 10 C.F.R. Part 100, and b) Regula-tory Guide 4.7.

3. The Clinch River site meets the requirements of:

a) 10 C.F.R. Part 100, and b) Regulatory Guide 4.7, in regard to site isolation and population density.

4. The meteorological measurement program for CRBRP meets the requirements of Regulatory Guide 1.23.

5. The X/Q (chi over Q) values calculated for CRBRP and set forth in Section 2.3 of the PSAR meet the requirements of Regulatory Guide 1.145.

6. The background frequency of genetic disorders in the population is of the order of 100,000 per million live born offspring.

7. A maximum estimate of the increased frequency of I genetic disorders at equilibrium as a result of a dose of 1 rem of radiation to the population per generation is of the order l

of 1,000 per million live offspring.

8. Estimates of the increase in genetic disorders as l a consequence of 1 rem radiation per generation, based on information

obtained directly from human exposure, show that such increases will be a very small fraction of the background frequency.

INTERROGATORIES For each admission which is denied in whole or in any part, provide the following for that portion which is denied:

(a) the specific portion or portions of the Admission which is denied; (b) the detailed basis for denial, if any.

If NRDC has insufficient information to admit or deny, it should describe in detail the reasons for and nature and extent of that in-sufficiency; (c) an identification of all documents ,

which support the basis for denial; (d) whether NRDC intends to rely upon the matters set forth in paragraphs (a) and (b) above in support of its position at the forth-coming hearings.

Respectfully submitted, M M Gforg A . Edgar V f f Attorney for Projdef Management l

Corporation

( Warren E. Bergholz J . /

Attorney for the e rpent of Energy

UNITED STATES Cr .4hERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:

• • • Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California P.O. Box 247 Bodega Bay, California 94923

• • • Mr. Gustave A. Linenberger Atomic Safety & Licensing Board Nuclear Regulatory Commission Washington, D.C. 20545

• Daniel Swanson, Esquire '

Stuart Treby, Esquire Office of Executive Legal Director Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

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• Atomic Safety & Licensing Appeal Board Nuclear Regulatory Commission Washington, D.C. 20545

• Atomic Safety & Licensing Board Panel Nuclear Regulatory Commission Washington, D.C. 20545 l

• Docketing & Service Section Office of the Secretary Nuclear Regulatory Commission Washington, D.C. 20545 (3 copies)

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Michael D. Pearigen, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37820 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)

• • Dr. Thomas Cochran Barbara A. Finamore, Esquire Natural Resources Defense Council, Inc.

1725 Eye Streat, N.W.

Suite 600 Washington, D.C. 20006 (2 copies)

Mr. Joe Walker 401 Roane Street Harriman, Tennessee 37748

, Ellyn R. Weiss, Esquire

! Harmon & Weiss 1725 Eye Street, N.W.

Suite 506 Washington, D.C. 20006

Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge P.O. Box 1 Oak Ridge, Tennessee 37830

• • Leon Silverstrom, Esquire Warren E. Bergholz, Jr., Esquire Department of Energy 1000 Independence Avenue, S.W.

Room 6B-256 Washington, D.C. 20585 (2 copies)

• • Eldon V. C. Greenberg, Esquire Tuttle & Taylor 1901 L Street, N.W.

Suite 805 Washington, D.C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building Suite 1007 Nashville, Tennessee 37219 A

l ey f ject Management Corporation l

DATED: October 4, 1982 l

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• / Denotes hand delivery to 1717 H Street, N.W, Washington, D.C.

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• • / Denotes hand delivery to indicated address.

• • • / Denotes hand delivery to 4350 East-West Highway, i Bethesda, Maryland.

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