ML20065P961

Supplemental Response to Second Set of Admissions & Seventh Set of Interrogatories

ML20065P961
Person / Time
Site:	Clinch River
Issue date:	10/21/1982
From:	Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
Shared Package
ML20065P964	List: ML20065P961 ML20065P989
References
NUDOCS 8210260397
Download: ML20065P961 (4)

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October 22, 1982 OCT 22P4;gy UNITED STATES OF AMERICA S ./ ,; hf' # R-NUCLEAR REGULATORY COMMISSION Shf Eh [gY 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 ) Docket No. 50-537

• PROJECT MANAGE!iENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB SUPPLEMENTAL RESPONSE TO APPLICANTS' l SECOND SET OF ADMISSIONS AND SEVENTH SET OF i

INTERROGATORIES DATED OCTOBER 4, 1982 Pursuant to 10 CFR S 2.740 (e), Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, hereby supplement their response to Requests for Admissions Nos. 1, 6, 7, and 8, of Applicants Second Set of Admissions, as well as to that portion of Applicants' l Seventh Set of Interrogatories relatinc to those Requests for Admission.

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The responses contained herein replace completely the responses provided by Intervenors on October 18, 1982.

REQUEST FOR ADMISSION Admission

1. NUREG-0625 has not been adopted by the Nuclear Regulatory Commission as nuclear reactor siting requirements i

in regard to site isolation and population density.

Response

1. Intervenors can neither admit nor deny this statement since the statement does not call for an admission as to any relevant matter of fact, but calls for a legal conclusion on which the NRC regulations speak for themselves.

Admission

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

Response

l 6. Intervenors can neither admit nor deny this statement without l

l a more precise definition of what constitutes " genetic disorders."

l See The Effects on Populations of Exposure to Low Levels of Ionizing Radiations, Report of the Advisory Committee on the Biological Effects of Ionizing Radiations (BEIR I Report), 1972, at 56.

Admission

7. A maximum estimate of the increased frequency of genetic disorders at_ equilibrium as a result of a dose of 1 rem of radiation to the population per generation is on the order of 1,000 per million live offspring.

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Response

7. Intervenors admit this statement to the extent that a maximum estimate was made by the BEIR-III Committee of the increased frequency of " human hereditary disorders" as a result of a dose of 1 rem of parental exposure received in each generation, before conception, which was 1100 per million liveborn offspring, which is on the order of 1,000 per million liveborn offspring. Intervenors deny that this is the only

" maximum estimate" made. Furthermore, the rate of disorders /

rem of parental exposure depends on what diseases are included in the term " genetic disorders." See response to Request for Admission # 6 above.

Admission

8. Estimates of the increase in genetic disorders as a consequence of 1 rem radiation per generation, based on infor-mation obtained directly from human exposure, show that such increases will be a very small fracticn of the background frequency.

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8. Intervenors can neither admit nor deny this statement with-E out a more precise definition of what constitutes "a very small fraction."

Interrogatories l 1(d), 6(d), 7(d), 8(d)

Intervenors have not yet determined whether they intend to rely upon the matters set forth above in support of their l position at the forthcoming hearings.

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Respectfully submitted, vBarbara -

A. Finamore S. Jacob Scherr

. Natural Resources Defense Council, Inc.

1725 I Street, NW, #600 Washington, D. C. 20006 (202) 223-8210

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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 the Sierra Club Dated: October 21, 1982

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