ML20052B743

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Update to 770127 Response to NRDC & Sierra Club 760519 Eleventh Set of Interrogatories
ML20052B743
Person / Time
Site: Clinch River
Issue date: 04/29/1982
From: Swanson D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
National Resources Defense Council, Sierra Club
Shared Package
ML20052B744 List:
References
NUDOCS 8205030524
Download: ML20052B743 (10)


Text

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4/29/82 UNITED STATES OF AliEF.ICA f;UCLEAP DF.GULATORY COMMISSICf BEFCRE THE ATOMI,C SAFETY AND LICENSIt:0 BOAFD in the flatter of UNITED STATES DEPARTMENT OF EllERGY Docket No. 50-537 PROJECT f;At:/. CEMENT CORPORATION TENNESSEE VALLEY AUTH0P.ITY

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(ClinchRiverBreederReactor

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Plant)

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NRC STAFF'S UFDATED Af!SPERS TO NATURAL RESOURCES DEFEMSF COUNCIL, INC. AND Tite SIERRA CLUB, ELEVENTH SET OF IhTERECCATORIES TO NitCLEAR REGULATORY C0ft!!ISS10N S1 AFF Pursuant to the Licensing Board's Prehearing Conference Order of February 11, 1982, the Nuclear Regulatory Corriission Staff (Staff) hereby updates its Jeruary 27, 1977 response to Intervenors',fiatural Rescurccs Defense Council, Inc. and the Sierra Club Eleventh Set of Interrogatories to the Nuclear Regulatory Comissior, filed on flay 19, 1976. Attached hereto are the NRC Staff's answers to f: ROC's and the Sierra Club's irterrogatories together with the affidavits of Mr. Bill M.

fiorris and Mr. Jerry Swift. If On l' arch 4,1982, the parties in this proceedir.c developed a Frctccol for Discovery. NRDC has requestec that answers to irterrogatory questions be prcvideo in six parts. The following six parts are:

A)

Provide the direct answer to the question.

B)

Identify all docurrents ard studies, and the particular parts thereof, relied upon hy the 1]

The affidavits of Mr. Morris and Mr. Swift are unsigned. However, a copy of their signed and notarized affidavits will be filed shortly.

l 8 2 0 5 0 3 0.fA(

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-2 Staff, now or in the past, which serve as the basis for the answer.

In lieu thereof, at Staff's option, a copy of such document and study may be attached to the enswer.

C)

Identify principal documents and studics, 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 ard study may be attached to ttie answer.

b) loentify by name, title and affiliation the primary Staff employec(s) er censultant(s) who provided the answer to the question.

El Explain whether the Staff is presently enneced in or intends to engage in any further, on-guing research program which may affect the Staff's answer. This answer need be provided only in cases where the Staff intends to rely upon ongoing research not included in Section 1.5 of the PStR at the LWA or construction permit hearing cr the CR6R.

Failure to provide such an answer means that the Staff does r,ct irtend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.

F)

Identify the exoert(s), if any, vtich the Staff intends to have testify on the subject matter questioned. and state the qualifica-tions of each such expert. This answer may he provided for each separate question or for a group of relatcd questions. This answer need not be provided until the Staff has in fact identifed the expert (s) in question or determined that no expert will testify, as long as such answer provides reasoretle 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.

B)

All docuner,ts and studies, and the particular perts thereof, relied upon by the Staff new or in the past which serve as the basis for the answer are mertiened in the direct answer to the question unless otherwise noted.

s 1 C)

Therc vcre ro principal documents and studies specifically examied but not cited in (b) unless otherwise noted.

D)

The perc, title and affiliation of the Staff employee (s) or consultant (s) who provided the answer to the nuestion ere eveilable in the af fidavits.

E)

The Staff is not presently engaced in nor intends to engage in any further, on-going research program vbich may affect Staff's answer unless otherwise noted.

F)

At this tire. the Staff has not determined who will testify on the subject matter c.vestioned. Reasonable netice will be giten to all parties efter the Staff has made this determinat. ion. At that time, a statement of professicral qualifications will be provided for each witness.

Respectfully subnitted, 0"Md w

Daniel T. Swanson Counsel for NRC Staff Dated at Eethesda,11aryland this 29th day of April,1982

e 4

4-NRC STAFF'S ANSWERS TO NRDC'S AND THE SIERRA CLUB'S INTERR0GATORIES The NRC Staff has determined that previous responses to interrogatories #1 through #4, a through c and f, #5 through #50,

  1. 52, #56 through #68, #70 through #83 and #89 through #100 are still applicable and need no updating.

The following Interrogatories are based upon the letter from Mr. Denise to Mr. Caffey dated May 6,1976.

References in the Interrogatories to the " letter" are to that letter.

Interrogatory 1 Do the positions and statements in the letter represent the final position of the Staff on the matters discussed?

Interrogatory 2 If not, identify those which are tentative.

Interrogatory 3 Are there any Staff evaluations of the CRBR now underway which, when completed, could affect any of the comments and guidance'provided in the letter?

Interrogatory 4 If so, describe the evaluation, its possible impact on any of the comments and guidelines and its presently scheduled date of completion.

Response to Interrogatories #1 through #4 (d) and (e)

In NRC Staff Response to NRDC et al Eleventh Set of Interrogatories filed on January 27, 1977 (hereinafter referred to as Response to lith Set) on page 3, the first paragraph after (d) should be replaced by the following:

l l

The first paragraph under site suitability source is finn with the following exception. The Staff is currently evaluating the possibility that new information or policy l

might allow modification of the CP (vs. OL) conservatism factors applied to the Plutonium dose guidelines.

p On page 5 of the Response to lith Set, replace the first sentence on that page with the following:

The first sentence of the third paragraph is not firm.

The staff is currently reconsidering the specific requirements that containment venting may not be initiated prior to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> subsequent to a postulated CDA. This reconsideration will not extend to any of the general principles set forth in the May 6, 1976 letter. We will report on the results of our evaluation in the SER.

The staff also is currently considering the implication of the new CRBR heterogeneous core design on the core work energy which could result from a CDA. This evaluation could result in modi-fications to the 1200 me-sec core work energy,1000 pounds of sodium, and 10 percent vaporized core fuel inventory specified in the letter from Denise to Caffey of May 6,1076. Consequently, the requirements for head hold down and missile barrier devices and sodium fuel vapor deflectors are also being reconsidered. We will report our findings in the SER.

On page 6 of the Response to lith Set, replace the second complete para-graph on that page with the following:

> The seventh paragraph constitutes firm guidance in the sense that reasonable measures should be taken to further reduce residual risk from the accidents being discussed.

The non-venting approach for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not firm as discussed above for the first sentence of the third I

paragraph. The possible approach of venting through filters is an illustrative suggestion of the type of approach the staff envisioned, and is not a specific requirement, Interrogatory 51 Explain how the safety objective of no more than a 10-6 chance of an accident exceeding the 10 C.F.R. 100 dose guidelines is applied in i

evaluating the probability of earthquakes and establishing the safe shutdown earthquake for the CRBR.

Response

On page 18 of the Response to lith Set, replace the second sentence with the following:

The Staff is not currently evaluating the probability of earthquakes in this determination for CRBRP.

Interrogatory 53 Has the Staff identified which structures, systems or components of the CRBR require research and development to confirm the adequacy of their design:

Interrogatory 54 If so, which ones?

a

, Interrogatory 55 As to the structures, systems or components identified in the previous answer has the Staff completed its examination of the research and development program which will be conducted to resolve any safety questions associated with such structures, systems or components?

Response to Interrogatories #53 through #55 The Staff does not currently rely on probabilistic methods for establishing the seismic design criteria for nuclear power plants.

(However, probabilistic methods have been used in a confirmatory manner and to provide insight in evaluating seismic hazard at some nuclear power plants. Because of the uncertainty associated with probabilistic estimates it is the Staff's position that such studies are more appro-priate for relative comparison of seismic hazard rather than absolute determination.

Interrogatory 69 At what time in the life of the core is the source term calculation made?

Response

A)

In order to be conservative, the source term inventory used in forming the Site Suitability Source Term is taken as that calculated at a time when the inventory of fission products and transuranics together in the reactor vessel is approximately at a maximum, for example, at the end of equilibrium cycle before removal and refueling of core and blanket.

B)

Clinch River Breeder Reactor PSAR, Amendment 64, January 1982.

. Interrogatory 84 Do the spectrum of calculations performed by the Staff in developing the accident consequences listed on page 5 of the letter represent the Staff conclusions as to the consequences of a CDA?

Interrogatory 85 If not, what do they represent?

Interrogatory 86 If yes, are these conclusions based upon completion by the Staff of 7

the analysis of CDA consequences to the same depth and breadth as the analysis which the Staff would undertake if the CDA were the DBA?

l Interrogatory 87 l

If not, in what specific respects does it differ?

Interrogatory 88 If not, why not?

l Response to Interrogatories #84 through #88 l

l' A)

On page 25 of the Response to lith Set, add the following sentence to the prior response:

See also tha response to 4:,'t n rgatories #1 and #4.

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF BILL M. MORRIS I, Bill M. Morris, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Section Leader of the Technical Review Section, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatories #1 through #68 and #70 through #100 of the lith Set and I hereby certify that the answers given are true to the best of my knowledge.

Bill M. Morris Subscribed and sworn to before me this day of April, 1982.

Notary Public My Conmission expires:

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY

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Docket No. 50-537 PROJECT MANAGEMENT CORPORATION

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TENNESSEE VALLEY AUTHORITY

)

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(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1.

I am employed by the U.S. Nuclear Regulatory Commission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2.

I am duly authorized to participate in answering Interrogatory #69 of the lith Set and I hereby certify that the answers'given are true to the best of my knowledge.

Jerry J. Swift Subscribed and sworn to before me this day of April, 1982.

Notary Public My Commission expires:

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