ML20049B928
| ML20049B928 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 09/30/1981 |
| From: | Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | CITIZENS FOR NUCLEAR REACTOR SAFETY, INC. |
| Shared Package | |
| ML20049A939 | List: |
| References | |
| NUDOCS 8110020397 | |
| Download: ML20049B928 (8) | |
Text
09/30/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ARMED FORCES RADI0 BIOLOGY RESEARCH )
Docket No. 50-170 INSTITUTE (Renewal of Facility License No. R-84)
(TRIGA-Type Research React r)
NRC STAFF'S FIRST SET OF INTERROGATORIES TO INTERVENOR CNRS The NRC Staff hereby requests that Intervenor, Citizens for Nuclear Reactor Safety (CNRS), pursuant to 10 C.F.R. 9 2.740b and in accordance with the Atomic Safety and Licensing Board's Special Prehearing Conference Order of August 31, 1981, answer separately and fully, in writing under oath or affirmation, the following interrogatories.
For each response to the interrogatories set forth below, identify the person or persons who prepared or substantially contributed to the preparation of the response.
The NRC Staff further requests that Intervenor CNRS, pursuant to 10 l
C.F.R. 6 2.741, provide copies of, or make available for Staff inspection and copying, those documents designated by CNRS in response to the accompanying interrogatories.
l General Matters
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1.
(a) State the names, address and professional qualifications of the pei son or persons upon whose views Intervenor relies to substantiate each contention, and/or whom Intervenor will present as an expert witness at hearing.
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(b) State by author, title, date of publication and publisher all books, tests and papers upon which each person named in the response to Interrogatory 1(a) and the Intervenor relies to substantiate his or her views.
(c) Describe all independent calculations, physical and mathematical models upon which each person named in 1(a) or the Intervenor relies to substantiate that person's views.
(d)
Provide summaries of the views, positions or proposed tastimony of each person named in 1(a) whom Intervenor will piasent as an expert witness at hearing.
(e) State by author, title, date of publication and publisher, 3
all books, documents or papers that you intend to employ or g
rely upon in conducting your cross-examination of prospective NRC Staff witnesses testifying in connection with each contention.
2.
(a) Have you admitted each statement included in the September 30, 1981 NRC Staff Request for Admissions by Intervenor CNRS?
(b)
If the answer to Interrogatory 2(a) is no, identify each statement in the Request for Admissions which you do not admit.
3.
For each statement identified in Interrogatory 2(b) give the following information:
(a) The portion of statement which is not admitted.
(b) The basis of your disagreement with the statement.
(c) The experts, if any, you are relying on in disagreeing with the statement.
(d) The documents, if any, you are relying on in disagreeing with the statement.
(e) The articles, if any, you are relying on in disagreeing with the statement.
STIPULATED CONTENTIONS Contention 1 1.
Quote the specific words where the HSR assumes that cladding failure during a pulse operation or inadvertent transient would occur at a peak fuel element temperature Of less than 100*C?
2.
Why do you contend that cladding failure would be "much more likely" to occur at elevated fuel temperatures?
3.
What is the quantity of fission product gap activity and fission prcduct releases you contend would result from elevated fuel temperatures (in excess of 400 C.)?
Contention 2 4.
Identify the authorized experiments of AFRRI whose failure could lead to radioactive releases in the reactor room.
5.
For each of the experiments identified in 4. above, state the radionuclides and quantity of radioactivity which could be released to the reactor room.
6.
For each experiment identified in 4. above, state the quantity of radioactivity which could be released offsite and describe the mechanism of such release.
. 7.
In dat manner do you consider the lead shielding doors and the reactor core pr ition safety interlock to be confinement safeguards?
8.
For the part of Contention 2 which refers to the " failure of built-in safeguards," describe the specivic human error and series of events resulting in releases of radioactivity in excess of " regulatory limits" for each of the malfunctions listed as (a) through (g), and identify the " regulatory limits" you contend could be exceeded.
9.
What do you mean by " moderating effect" of the hydrogen nuclei?
10.
By what mechanism would the presence of damaged fuel elements significantly reduce the " moderating effect" of the hydrogen nuclei?
11.
Do you contend that it is necessary that the negative temperature coefficient be able, alone, and at all timas, to completely shut down the reactor?
- 12. What is the maximum number of fuel elements that you contend could credibly fail at one time?
13.
For each of the initiating events, (a) through (d), identifed in part (4) of Contention 2, describe the mechanism of multiple fuel clement cladding failure and state the quantity of fission products you expect to be released compared to the fuel element failure described in the HSR.
Contention 4
- 14. What is the basis of your statement that Applicant's radiation monitoring methods and corrective actions are " inadequate to detect and prevent the recurrence" of violations of regulatory limits?
- 15. What fonn of routine radioactive emissions from AFRRI could cause radiation doses due to inhalation or ingestion?
. 16. What sources of radioactivity which are routinely emitted from the AFRRI facility cause significant biological doses by other than gamma radiation?
17.
State the quantities of radioactivity identified in 16. abctc which you contend will be routinely emitted from the AFRRI facility.
- 18. What particulates do you contend would be released routinely to the air after passing through the filter system?
- 19. With respect to the particulate radioactivity monitor, explain why its being " isokinetic" would provide " meaningful evaluatien".
- 20. Do you contend that Applicant's Gross Beta Effluent /nalysis methods are still in violation of environmental sampling and analysis procedures?
21.
If the answer to 20. above is yes, state the basis for your answer.
- 22. With regard to Applicant's " Environmental Sampling and Analysis" program, what do you consider to be " adequate information"?
- 23. Why is the " concentric cylinder set model" used by the Applicant
" unrealistic"? Describe what you consider a realistic model.
- 24. What is the basis for your statement that it is " highly probable" 10 C.F.R. Part 20 limits were exceeded because of the leak in the ventilation exhaust stark drain line?
l 25.
For 24. above, provide calculations to support your " highly probable" characterization.
26.
Regarding the Airborne Release Reports of 1962 through 1964, do you contend that the Argon-41 currently exceeds the maximum permissible concentration, and if so, give the basis for your contention?
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. 27. Are you aware of any changes made to the AFRRI facility since the Reports of 26. above which would alter either the amount or concen-tration of Argon-41 released to the atmosphere?
UNSTIPULATED CONTENTIONS Contention 1
- 28. What do you mean by " rapid" loss of coolant?
- 29. How long do you contend the reactor would remain in the pulse mode, and explain your understanding of " pulse mode"?
- 30. What quantity of fission products do you contend would be released?
31.
Identify any documented cases in which a TRIGA reactor suffered a loss of coolant in the pulse mode which caused multiple cladding failures.
32.
Identify any documented instances in which stainless steel clad TRIGA reactor fuel suffered cladding failure due D high temperatures during reactor operating or accident conditions.
33.
Demonstrate by calculation how the AFRRI reactor could lose coolant and experience a sudden temperature elevation.
Contention 2
- 34. Describe the mechanism which could cause a power excursion accident.
- 35. How would multiple cladding failures reduce the thermalizing effect of hydrogen? Exp'ain your understanding of "thermalizing effect of hydrogen."
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- 36. What calculations do you have to demonstrats that a LOCA would cause multiple cladding failures?
- 37. What is your basis for claiming that zirconium hydride reacts
" explosively" with steam and air? Specifically identify all documentation supporting your claim.
The Intervenor's attention is directed to 10 CFR $ 2.740(e)(1)-(3) which sets forth a duty to supplement certain responses to interrogatories upon the acquisition of further knotiledge. This section requires supple-ments to interrogatories to provide information concerning persons with knowledge of discoverable matters; identity of expert witnesses; and corrections and/or changes in previous responses.
RespectfJlly submitted,
~
Richard G. Bachmann Counsel for NRC Staff Dated at Bethesda, Maryland this 30th day of September,1981
UNITED STATES OF AliERICA fiUCLEAR REGULATORY C0fiMISSION BEFORE THE ATOMIC SAFETY AllD LICEf4 SING B6ARD In the Matter of
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Docket No. 50-170 ARMED FORCES RADI0 BIOLOGY RESEARCH
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INSTITUTE
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(Renewal of Facility
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License No. R-84)
(TRIGA-Type Research Reactor)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF REQUEST FOR ADMISSIONS BY INIERVEICR CNRS" and "NRC STAFF'S FIRST SET OF INIERROGATORIES TO INIERVEtM CNRS" in the above-cr*Caed proceeding have been served on the following by deposit in the United.
- s mail, first class, or, as indicated by an asterisk, through deposit in the Mulear Regulatory Conmission's internal mail sy:, ten, this 30th day of 4
September, 1981:
Louis J. Carter, Esq., Chairman lis. Elizabeth B. Entwisle Administrative Judge 8118 Hartford Avenue Atomic Safety and Licensing 6oard Silver Spring,110 20910 23 Wiltshire Road Philadelphia, PA 19151 Atonic Safety and Licensing Board Panel
- Mr. Ernest E. Hill U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 Lawrence Livermore Laboratory University of California Atonic Safety and Licensing Appeal P.O. Box 808, L-123 Panel (5)*
Livermore, CA 94550 U.S. Nuclear Regulatory Conmission Washington, DC 20555 Dr. David R. Schink Administrative Judge Docketing and Service Section*
Department of Oceanography Office of the Secretary Texas A&M University U.S. Nuclear Regulatory Commission College Station, TX 77840 Washington, DC 20555 Mr. Robert L. Brittigan, Esq.
General Counsel Defense Nuclear Agency Washington, DC 20305 Richard G. Bachtnann Counsel for NRC Staff
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