ML20052C494
| ML20052C494 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/30/1982 |
| From: | Ogg W JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205050048 | |
| Download: ML20052C494 (14) | |
Text
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4/30/82
.' y,\ ,11 UNITED STATES OF AMERICA , , , ,
NUCLEAR REGULATORY COMMISSION APR33 , @
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e In the Matter of ) N
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UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
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TENNESSEE VALLEY AUTHORITY )
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APPLICANTS' UPDATED RESPONSE TO .
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NATURAL RESOURCES DEFENSE COUNCIL, INC2 s s
AND THE SIERRA CLUB NINTH SET OF ' l' d INTERROGATORIES TO APPLICANTS Pursuant to 10 CFR 2.740b, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy, Proj ect Management Corporation, and the Tennessee Valley Authority (the Applicants) hereby file their responses to the Natural Resources Defense Council, Inc. and the Sierra Club Ninth Set of Interrogatories to the Applicants , dated May 13, 1976.- /
- ] Applicants previously responded to these interroga-tories on June 4,1976. Applicants have prepared these updated responses to establish a current base of information for the CRBRP for the purpose of expediting these proceedings. Accordingly, in providing these responses, Applicants do not concede that the information contained therein is admissible in or 9 S
, necessary to a decision in the LWA proceeding.
l Continued I /
i 8205050048 820430 l PDR ADOCK 05000537 l 0 PDR
O 2-Answers 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 the reo f , relied upon by Applicants, now or in the past, which se rve as the basis for the answer. In lieu thereof, at Applicants' option, a copy of such document and study may be attached to the answe r.
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.
Applicants have not furnished copies of or made available for inspection and copying those documents referenced in this response which were previously referenced and made available pursuant to the Applicants' previous responses. Documents referenced for the first time in this update response will be made available upon request. General questions and responses follow the protocal agreed u parties and attached to Mr. Greenberg'pon by the s march 8,1982 letter to Counsel for PMC.
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ANSWER: Unless otherwise indicated below in regard to the answer under the heading
" DOCUMENTS"; none.
(d) Identify by name, title and affiliation the primary Applicant employee (s) or consultant (s) who provided the snswer to the question.
ANSWER: See the attached affidavits.
(e) Explain whether Applicants are presently engaged in or intend to engage in any further, ongoirs research program which may affect Applicants' answer. This answer need ;
be provided only in cases where Applicants i
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 hearing 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 intend to have testify on the ,
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subj ect 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 i
questions. This answer need not be provided until Applicants have in fact identified the expe rt(s) in question or detennined that no expert will testify, as long as such answer ;
i provides reasonable notice to Intervenors.
f ANSWER: Applicants have not yet identified the ,
expert (s) in question.
Answe rs to Specific Questions i
Inte rroga to ry.
III. It has been the admonition of the ICRP, the NRCP, the ,
FRC and the NRC/AEC that radiation exposures should be kept as far below the permissible levels as is practicable. This has recently been termed ALARA.
- 1. Is the purpose of this admonition or ALARA simply to limit the radiation dose or is its purpose to limit the biological damage incurred in the exposed individuals?
Answer.
III. 1. The term "as low as reasonably achievable" (ALARA) is codified in the applicable NRC
regulation 10 CFR 20.1 (c) . This term was adopted by an amendment which appeared in the Federal Register on December 19,1975 (40 FR 58847) . This Federal Register Notice indicates that the ICRP recommendation on dose limitation in ICRP Publication No. 22 was the origin for the amendment.
Inte rroga to ry.
III. 2. Radiation exposure can cause both somatic and genetic effects in man. Is the purpose of ALARA to limit somatic or genetic effects or both?
Answer.
III. 2. A single or mutually exclusive choice of purposes cannot be ascribed to ALARA. The purpose of ALARA is to maintain radiation exposures and releases of radioactive materials to unrestricted areas "as low as reasonably achievable". The definition of the term "as low as is reasonably achievable" would seem to reflect a number of purposes:
The term "as low as is reasonably achievable" means as low as is reasonably achievable taking into account (1) the state of technology, (2) and the economics of improvements in relation to benefits to the public health and safety, and other societal and accioeconomic considerations, and in relation to the utilization of atomic <
energy in the public interest.
Inte rroga to ry .
III. 3. In considering whether the occupational exposures for the CRBR plant are ALARA, has there been or will there be any special consideration given to the genetic dose and effects as opposed to somatic dose and effects?
i) If yes, precisely what considerations?
- 11) If not, why not?
Answer.
III. 3. No, since existing regulations do not require that special consideration should be given to genetic dose or effects for occupational exposure.
Inte rroga to ry.
III. 4. In considering whether the occupational exposures for the CRBR plant are ALARA, has there been or will there be any special consideration given to the exposure of pregnant women or fertile women in the childbearing age?
i) If yes, precisely what considerations? ,
- 11) If not, why not?
r Answer.
III. 4. At the present time the applicable NRC regulations (10 CFR 20.1(c)) do not impose such a require-ment. However, the Applicants intend to comply with the requirements of Regulatory Guides 8.8, 8.10, and 8.13. It should be noted that the Commission has proposed a rule
F dealing with pregnant women. The Applicants will comply f with appropriate and approved regulations.
Inte rrogato ry.
l III. 5. Is it not true that the occupational exposure of pregnant women and the gonads represent a special class of exposure in that the effects are not suffered by the workers, but by their children and future generations?
i) Don' t these exposures actually correspond to the exposure of the general public? In your answer, consider the fact that the damaged genes and ct. mosomes of the workers become admixed with the general population.
Answer.
III. 5. As noted in 4 above, the occupational exposure of pregnant women will be given particular attention. It should be noted that the Commission has proposed a rule dealing with this subject. The Applicants will comply with appropriate and approved regulations. As l for occupational exposures to the gonads, the answer pro-vided in 3. above indicates that NRC has not felt it necessary or appropriate to require that special considera-
, tion be given to genetic dose or effects for occupational exposures.
Inte rrogato ry .
III. 6. The NRS Committee on the Genetic Effects of Atomic radiation made the following recommendation:
F) That every effort be made to assign to tasks involving higher radiation exposures individuals who, fo r age o r other reasons, are unlikely thereaf ter to have additional offspring. Again, it is recognized that such a procedure will introduce complications and difficul-ties, but this committee is convinced that society should begin to modify its procedures to meet inevitable new conditions. (NAS BEAR Repo rt, National Academy of Sciencer, The Biological Effects of Atomic Rtdiation, Summary Reports, Report of che Committee on -
Genetic Effects of Atomic Radiation, Washington, D.C., 1956, p. 29.)
Will this recommendation be implemented with respect to the CRBR?
i) If yes, in what manner?
- 11) If not, why no t?
Answer.
III. 6. As indicated in response to III-4, the Applicants are committed to meeting the requirements of 10 CFR 20.1(c) and Reg. Guides 8.8, 8.10, and 8.13 in connection with ALARA. The types of considerations mentioned in Question 6 are not required by the regulations, i
and the Applicants are not considering implementing them.
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Inte rroga to ry.
III. 7. The NCRP made the following recommendation: During the entire gestation period the maximum permissible dose equivalent to the fetus from occupational exposure of the
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expectant mother should not exceed 0.5 rem. (NCRP Report No. 39, Basic Radiation Protection Criteria, National Council on Radiation Protection and Measurement, Washington, D.C., 1971, p. 92. ) Will this recommendation be implemented with respect to the CRBR?
i) If yes, in what manner?
- 11) If not, why not?
Answer.
III. 7. As indicated above, the Applicants are committed to implementing Reg. Guide 8.13 which deals with the exposure to women of child bearing age. It is noted that the Commission has proposed a rule dealing with this subj ec t . The Applicants will comply with appropriate and approved regulations.
Inte rroga to ry.
III. 8. Wq_uld it not be possible to implement the recommendations cited in 6 and 7 above by operating the CRBR with the- following guidelines:
- 1) For individuals under the age of 45, the whole body radiation exposure limit shall not exceed 0.5 l
aw rem in any calendar year and 0.3 rem in any calendar quarter.
- 11) For individuals equal to or greater than 45 years of age, an individual may receive up to 3 rem / quarter whole body dose as long as the dose to the wole body shall not exceed 0.5 (45-18) + 1.5 (N-45) rem, where N equals the individual's age in years. In your answer, consider the following:
Data on results of personnel monitoring reported to the Commission pursuant to S 20.407,10 CFR Part 20, for calendar year 1973, indicate that 67,862 individuals were monitored, 29,169 receiving measurable exposures averaging 0.73 rem for the year, and 3,425 individuals (11.8 percent of those receiving measurable exposures) had estimated exposures in excess of 2 rems. Fede ral Register, Vol. 40, No. 2, Friday, January 3,1975,
- p. 799.
a) If not, why not?
Answer.
III. 8. As indicated in the previous responses, the Applicants are committed to meeting the current regulations. It is noted that the Commission has proposed a rule dealing with planned special exposures. The Applicants will comply with appropriate and approved regulations.
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- l UNITED,5TATFS OF AMERICA l -
.NUCLEARREGULhTORYCOMMISSION In the Matter of '
l U. 5. DEPARTMENT OF ENERGY DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION, .
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and TENNESSEE VALLEY AUTHORITY . .-
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AFFIDAVIT OF WENDALL W. OGG Wendall W. Ogg being duly sworn, deposes and says as follows:
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- 1. That he is employed as Nuclear Engineer, Public Safety .
Division CRBRP Project, and that he is d0ly authorized to answer Inter-rogatories ITT l-8 of the ninth set of Interrogatories. '
- 2. That the above mentioned and attached answers are true and correct t'o the best of his knowledge and belief. -
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., ignature t
t SUBSCRIBED and SWORN to before me -
this _J_o,, day of Ap/2j,l_ 1982 U _Jh 'd Notary Wilic -
My Comtnissico Expiros April 28.192.: -
9019-9E9 Sid 2001B XBO 38883 IWD 60:GT 002/WWO
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UNITED STATES OF AMERICA
, NUCLEAR REGULATORY COMMISSION ,
l i
)
In the Matter of ) ,
)
UNITED STATES DEPARTMENT OF ENERGY ) ,
) !
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
) i TENNESSEE VALLEY AUTHORITY ) *
)
(Clinch River Breeder Reactor Plant) ) '
)
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 Concission 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) 1 l
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-2_
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- Atomic Safety & Licensing Appeal Board [
U. S. Nuclear Regulatory Commission ,
Washington, D. C. 20545 ,
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- Atomic Safety & Licensing Board Panel '
U. S. Nuclear Regulatory Commission '
Washington, D. C. 20545
- Docketin & Service Section Office o the Secretary U. S. Nuclear Regulatory Commission 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 Nashville, Tennessee 37219 '
Dak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire i 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) I
- 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 Harriman, Tennessee 37748 !
Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006 i
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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 Oak 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 A
GeorgVL. EdgF Attorney for Troject Management Corporation DATED: April 30, 1982
- / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
- / Denotes hand delivery to indicated address.