ML20052B179
| ML20052B179 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/27/1982 |
| From: | Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | National Resources Defense Council, Sierra Club |
| Shared Package | |
| ML20052B165 | List: |
| References | |
| NUDOCS 8204300126 | |
| Download: ML20052B179 (10) | |
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04/27/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of U.S. DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant) )
NRC STAFF'S ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TWENTY-FIRST SET OF INTERR0GATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF Pursuant to the Licensing Board's Prehearing Conference Order of Februa ry 11, 1982, the Nuclear Regulatory Commission Staff (Staff) hereby responds to the Natural Resources Defense Council, Inc. and the Sierra Club Twenty-first Set of Interrogatories to the Nuclear Regulatory Commission Staff filed on April 18, 1977. Attached hereto are the Staff's answers to NRDC's and the Sierra Club's interrogatories, J
together with the affidavit of Mr.. Cardis L. Allen.1/
f On March 4, 1982, the parties in this proceeding developed a Protocol for Discovery. NRDC has requested that answers to interro-gatory questions be provided in six parts. The following six parts are:
A)
Provide the direct answer to the question.
1/ The affidavit of Mr. Cardis Allen is unsigned.
However, a copy of his signed, notarized affidavit will be filed shortly.
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. B)
Identify all documents and studies, and the particular parts thereof, relied upon by the Staff, now or in the past, which serve as the basis for the answe'r, In lieu thereof, at Staff's option, a copy of such doct; ment and study may be attached to the answer.
C)
Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (b).
In lieu thereof, at Staff's option a copy of each such document and study may be attached to the answer.
D)
Identify by name, title and affiliation the primary Staff employee (s) or consultant (s) who provided the answer to the question.
E)
Explain whether the Staff is presently engaged in or intends to engage in any further, on-going research program which may affect the Staff's answer. This answer need Se provided only in cases where Staff intends 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 the Staff does not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.
F)
Identify the expert (s), if any, which the Staff intends 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 the Staff has 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.
For all the responses to interrogatories in this set the following are the answers to the requested parts in the Protocol for Discovery.
l B)
All documents and studies, and the particular parts thereof, relied upon by the Staff now ar in the past which serve as the basis for the answer are mentioned in the direct answer to the question unless otherwise noted.
C)
There were no principal documents and studies specifically examined but not cited in (b) unless l
othemise noted.
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. D)
The name, title and affiliation of the Staff employee (s) or consultant (s) who provided the answer to the question are available in the affidavits.
E)
The Staff is not presently engaged in nor intends to engage in any further, on-going research program which may affect the Staff's answer unless otherwise noted.
F)
At this time, the Staff has not determined who will testify on the subject matter questioned.
Reasonable notice will be given to all parties after the Staff has made this determination. At that time, a statement of professional qualifica-tions will be provided for each witness.
i Respectfully submitted, h
Daniel T. Swanson Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of April,1982.
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NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S INTERR0GATORIES These interrogatories are keyed to the underlined and numbered statements on the enclosed copy of the appropriate pages of NUREG-0122, "An Analysis and Evaluation of the CRBR Core Disruptive Accident Energetics."
(The enclosed copy is attached to Natural Resources Defense Council, Inc. and the Sierra Club Twenty-First Set of Interrogatories to the Nuclear Regulatory Commission Staff dated April 18,1977.)
Interrogatory 1
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Precisely what is meant by "sufficiently low probability"?
(a) Since the Staff is unable to give a quantitative value for the probabiliity of a CDA, how is it possible to determine that it is sufficiently low?
(b)
Is a probability of 0.01 sufficiently low?
(c)
Is a probability of 0.001 sufficiently low?
(d)
Is a probability of 0.0001 sufficiently low?
Interrogatory 2 What is meant by a " reasonable and rational level" in this context?
(a)
Is a energetic level of 2400 MJ reasonable?
(1)
If not, why not?
(b)
Is an energetic level of 2400 MJ rational?
(ii) If not, why not?
Interrogatory 3 I
Precisely what is meant by "potentially enveloping"?
(a)
Isn't it true that energetics larger than 1200 MJ-sec are possible?
_2-Interrogatory 4 What is meant by " substantial fuel motion"?
(a) How has it been determined that during the initating phase of a real incident these limitations and assumptions are to be expected?
Interrogatory 5 What is the precise basis for this assumption?
(a)
Isn't it reasonable to assume that a number of pins will fail at less than the 0.5 melt fraction?
(b) Would pin failures at lower melt fractions cause a more rapid sodium void and an increased ramp rate?
Interrogatory 6 Has the Staff utilized other channel arrangements (that is, except for the Staff's and the Applicants')?
(a)
If not, why not?
(b)
Isn't it possible that other channel arrangements would lead to higher energetics?
(c) Of the two, which is better, the Staff's or the Applicants'?
Interrogatory 7 Is this higher coherence more or less respresentative of the expected initiating phase? Please explain your answer in detail.
(a)
In answering this question, consider your answer to interrogatory 5 above.
Interrogatory 8 l
Is it not possible that another channel arrangement would lead to a ramp rate greater than 70$/sec?
(a) Since the Staff's reference case is neither the "best value" or "most probable," isn't it reasonable to assume that ramp rates in excess of 70$/sec are quite probable?
(i)
If not, why not?
Interrogatory 9 Isn't it also correct that this approach can lead to ramp rates which are not conservative?
(a)
If not, why not?
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_ (b) At what point (values) can it be demonstrate that the assumed pressure and inital velocity are conservative? Explain your answer in detail.
Interrogatory 10 At these points in analysis, is it required that the SASBA analysis has predicted the course of events, in these phases sodium boiling, clad melting, fuel melting, clad and fuel motion are occurring and enough fuel for several critical masses is available. Events are occurring on millisecond or less time scales, yet parametric analysis leads to time differences for events that are seconds apart. How is it possible for the Staff to arrive at conclusions relative to the energetics form this montage?
Interrogatory 11 This interrogatory is interrelated with 10 above. Here it is stated that engineering judgment is the basis for the Staff's position. Please explain in detial the analysis performed by the Staff to reach its position.
(a) Please supply all reports, memoranda and internal documents that relate to this analysis.
(b) How was it datermined that a recriticality in one portion of the core could not Sad to recriticalities with significant ramp rates in other portions of one core?
Interrogatory 12 In section 5.0 (Mechanical Disassembly Phase) of this report, a number of problems associated with VENUS-II inputs are discussed.
In Section 3.0 (Initiating Phase), a number of problems assocaited with SAS3A were discussed.
In this section the problem of interfacing SAS3A and Venus-II is discussed as well as other problems. Clearly, depending upon the choices among the uncertainties, it would be possible to arrive at work energies well in excess of 1200 MW-sec.
Explain in detail how the Staff selected among these uncertainties to arrive at this opinion.
(a) Please make this explanation for each of the parameters and problems including those discussed under recriticality.
(b) Please supply all reports, memoranda and internal documents relating to this analysis.
(c) What is meant by the great majority of accidents?
(i) Precisely how was this determination made?
(ii) Didn't the Applicants' channel arrangement and the Staff's
reference parameters yield a ramp rate of 70$/sec and a work energy of 1200 MW-sec?
(d) How well are the material properities of the mixture of fuel, steel, fission products and sodium known?
(i)
Isn't it possible that the properties leading to fuel-steel-coolant interactions could be substantially different for such mixtures?
(e) What is the bounding value for the energetics of a CRBR-CDA?
Response to Interro;otories #1 through #12 A)
The subject of these interrogatories is the Staff's report on its evaluation of CDA energetics for the old homogeneous core, with j
the advent of the new CRBR core design the Staff is re-evaluating many of its earlier calculational results.
It is expected that many specifics of those analyses and findings will change.
Like other interrogatories dealing with specifics of old analyses it is the Staff's intent that the subjects will be addressed in its SER Which will be issued in the spring of 1983.
In set 21 this applied particularly to questions 4-12.
It is believed that questions 1-3 have been responded to elsewhere.
For question 1 see the answers to interrogatory set 14, Part I, questions 1-4 and Part IX, questions 1-5 (see also for Pequest Admissions, set 8 (dated 1/14/77)). For questions 2-3 of set 21 see the answers to interrogatory set 16, questions 1-4.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORIIY (Clinch River Breeder Reactor Plant) )
AFFIDAVIT OF CARDIS' L. ALLEN
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I, Cardis L. Allen, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.
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2.
I am duly authorized to participate in answering Interrogatories #1 through #12 of the 21st Set and I hereby certify that the answers l
given are true to the best of my knowledge.
Cardis L. Allen Subscribed and sworn to before me this day of April,1982.
1 Notary Public My Comission expires:
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UNITED STATES OF AMERefHhned Ev NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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Docket No. 50-5 PROJECT MANAGEMENT CORPORATION
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I hereby certify that copies of "NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB REQUEST TO APPLICANTS AND STAFF FOR ADMISSIONS DATED AUGUST 17,1976", "NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC., AND THE SIERRA CLUB TENTH SET OF INTERR0GATORIES TO NUCLEAR REGULATORY COMMISSION STAFF", "NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND SIERRA CLUB REQUEST TO APPLICANTS AND STAFF FOR ADMISSIONS DATED JANUARY 14, 1977", "NRC STAFF'S UPDATED ANSWERS TO NATURAL RESOURCES DEFENSE i
COUNCIL, INC. AND THE SIERRA. CLUB NINTH SET OF INTERROGATORIES TO NUCLEAR REGULATORY COMMISSION STAFF", and "NRC STAFF'S ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE l
SIERRA CLUB TWENTY-FIRST SET OF INTERR0GATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, either through deposit in the Nuclear Regulatory Comission's internal mail system or hand delivered,
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this 27th day of April, 1982:
Marshall Miller, Esq., Chairman Administrative Judge William M. Leech, Jr., Attorney General Atomic Safety and Licensing Board William B. Hubbard, Chief Deputy Attorney General U.S. Nuclear Regulatory Commission Lee Breckenridge, Assistant Attorney Washington, D.C.
20555
- General 450 James Robertson Parkway Mr. Gustave A. Linenberger Nashville, Tennessee 37219 Administrative Judge Atomic Safety and Licensing Board DSC))
U.S. Nuclear Regulatory Commission
.s Washington, D.C.
20S55
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. George L. Edgar, Esq.
Mr. Joe H. Walker Frank K. Peterson, Esq.
401 Roane Street Gregg A. Day, Esq.
Harrimari', Tennessee 37830 Thomas A. Schmutz, Esq.
Irvin A. Shapell, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
William E. Lantrip, Esq.
Washington, D.C.
20036 City Attorney Municipal Building Project Management Corporation P.O. Box 1 P.O. Box U Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Lawson McGhee Public Library Barbara A. Finamore 500 West Church Street Ellyn R. Weiss Knoxville, Tennessee 37902 Dr. Thomas.B. Cochran St Jacob Sch' err Warren E. Bergholz, Jr.
Natural Resources Defense Council, Inc.
Leon Silverstrom 1725 Eye Street, N.W., Suite 600 U.S. Department of Energy l
Washington, D.C.
20006 1000 Independence Ave., S.W.
I Room 6-B-256 Manager of Power Tennessee Valley Authority 819 Power Buildin9 Dr. Cadet H. Hand, Jr., Director Chattanooga, Tennessee 37401 Administrative Judge Director"
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Bodega Marine Laboratory University of California Clinch River Breeder Reactor Plant P.O. Box 247 Project Bodega Bay, California 94923 U.S. Department of Energy Washington, D.C.
20585 Alan Rosenthal, Esq., Chairman Atomic Safety and Licensing Appeal Eldon V.C. Greenberg Board Panel Tuttle & Taylor U.S. Nuclear Regulatory Commission 1901 L Street, N.W., Suite 805 Washington, D.C.
20555 Washington, D.C.
20036 Dr. John H. Buck Atomic Safety and Licensing' Appeal Atomic Safety and Licensing Appeal Board Panel Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Wa'shington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section t
Office of the Secretary
[ M d-U.S. Nuclear Regulatory Commission Daniel T. Swanson Washington, D.C.
20555 Counsel for NRC Staff J