ML20054C693

Response to Sixteenth Set of Interrogatories.Certificate of Svc Encl

ML20054C693
Person / Time
Site:	Clinch River
Issue date:	04/16/1982
From:	Vallario E ENERGY, DEPT. OF
To:	National Resources Defense Council, Sierra Club
References
NUDOCS 8204210511
Download: ML20054C693 (9)

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4/20/82 UNITED STATES OF AMERICA T2 /g, y g , ,, ,.

NUCLEAR REGULATORY COMMISSION In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION )

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TENNESSEE VALLEY AUTHORITY ) 7./ , 3 (Clinch River Breeder Reactor Plant) ) g gpp[,3 }

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APPLICANTS' RESPONSE TO INTERVENORS',

NATURAL RESOURCES DEFENSE COUNCIL, INC.

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AND SIERRA CLUB, SIXTEENTH SET pa OF INTERROGATORIES TO THE APPLICANTS --

Pursuant to 10 C.F.R. 5 2.740b., the United States Department of Energy and Project Management Corporation, acting for themselves and on behalf of the Tennessee Valley Authority (the Applicants), hereby respond to Intervenors',

Natural Resources Defense Council, Inc., and the Sierra Club, Sixteenth Set of Interrogatories to the Applicants,

• /

dated March 18, 1982.

• / This Response addresses interrogatories Contention 11 Told 8) II, 2 and 3. The Applicants' March 29, 1982 Motion for A Protective Order objected to and sought relief from these Interrogatories. The Board's April 6, 1982 ruling during the prehearing meeting of counsel denied Applicants' Motion as to these interrogatories. This completes Applicants' responses to interrogatory set sixteen.

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.inswers to General Questions (a) -

(f)

(a) Provide the direct answer to the question.

ANSWER: See the direct answers below under heading " ANSWER".

(b) Identify all documents and studies, and the particular parts thereof, relied upon by Applicants, now or in the past, which serve as the basis for the answer. In lieu thereof, at Applicants' option, a copy of such document and study may be attached to the answer.

ANSWER: See the direct answers below under heading " DOCUMENTS".

(c) Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (b). In lieu thereof, at Applicants' option, a copy of each such document and study may be attached to the answer.

, ANSWER: Unless otherwise indicated below in l

l regard to the answer under the heading

" DOCUMENTS"; none.

l (d) Identify by nace, title and affiliation the l

primary Applicant employee (s) or consultant (s) l who provided the answer to the question.

ANSWER: See the attached affidavits.

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(e) Explain whether Applicants are presently engaged in or intend to engage in any further, ongoing research program which may affect Applicants' answer. This answer need be pro-vided only in cases where Applicants intend to rely upon ongoing research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR. Failure to provide such an answer means that Applicants do not intend to rely upon the existence of any such research at the LWA or construction permit hear-ing on the CRBR.

ANSWER: If not in Section 1.5 of the PSAR and the direct answer below; none.

(f) Identify the expert (s) if any, which Applicants intent 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 Applicants 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 Intervenors.

ANSWER: Applicants have not yet identified the expert (s) in question.

Answers to Specific Questions II. Contention 11 (old Contention 8)

2. Identify the latest EPA position with respect to proposed occupational exposure limits.

ANSWER: The latest EPA position on the " Federal Radiation Protection Guidance for Occupational Exposures" was published in the Federal Register, Volume 46 No. 15, Friday, January 23, 1981. The Federal Register notice was a request for written comments and was supported by the document below.

DOCUMENTS: Occupational Exposure to Ionizing Radiation in the United States - EPA 520/4-80-001.

3. Identify the latest Applicant position with regard to proposed occupational exposure limits.

ANSWER: The latest DOE position is reflected in (1) the oral testimony transmitted by Barton House, Acting Assistant Secretary for Environmental Protection, Safety and Emergency Preparedness (DOE) to W. A. Mills, Director, Criteria and Standards Division (EPA), dated April 17, 1981, and (2) written DOE comments dated July 10, 1981, transmitted by S. H. Greenleigh, Acting Deputy Assistant Secretary for Environment, Safety and Health to the Director, Criteria and Standards Division (EPA).

< DOCUMENTS: Copies of the foregoing documents will be made available for inspection and copying at the Office of General Counsel, United States Department of Energy. Contact Warren Bergholz (252-6975) to make arrangements for inspection and copying.

(a) Review of National Academy of Science BEIR III Report.

(b) Occupational Exposure to Ionizing Radiation in the United States - EPA 520/4-80-001.

(c) NCRP Report No. 39 " Basic Radiation Protection Criteria".

(d) DOE /EV-0045 (Rev 2-81) " Study of Anticipated Impact on DOE Programs from Proposed Reductions to the External Occupational Radiation Exposure Limits".

(e) ICRP Publication No. 26 " Radiation Protection," ICRP Publication No. 30 -

" Limits for Intakes of Radionuclides by Workers".

UNITED STATES OF MRICA NUCLEAR REGl1LATORY COMMISSION In the matter of .)

Department of Energy .)

DOCKET WO. 50-537 PRW ECT MANArdMENT CORPORATION and.)

TENNESSEE VALLEY AUTHORITY .)

AFFIDAVIT OF Edward Vallario, being duly sworn, deposes and says as follows:

1. That he is employed as Manager, Health Phy sics Program, Office of Nuclear safety, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered II.2 and 11.3 in the Sixteenth set.

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

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Signaturt

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$UBSCRIBED and SWORN to before me thf s g day of f , 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

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TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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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 U. S. Nuclear Regulatory Commission Washington, D. C. 20545 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 U. S. Nuclear Regulatory Commission Washington, D. C. 20545 ,

• Daniel Swanson, Esquire

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

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

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

• Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Co= mission Washington, D. C. 20545 (3 copies)

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway 4

Nashville, Tennessee 37219 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 1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 (2 copies)

Mr. Joe H. Walker 401 Roane Street Harri=an, Tennessee 37748 Ellyn R. Weiss 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, Esq.

Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Dak Ridge, Tennessee 37830 Leon Silverstrom, Esq.

Warren E. Bergholz, Jr., Esq.

U. S. Department of Energy 1000 Independence Ave., S. W.

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

• • Eldon V. C. Greenberg 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 Georgqfk? Edga Attorney for Project Management Corporation DATED: April 20, 1982

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

• • / Denotes hand delivery to indicated address.

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