ML20052D191
| ML20052D191 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 05/04/1982 |
| From: | Cooperstein R, Murdock J, Switick D JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205060349 | |
| Download: ML20052D191 (96) | |
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UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION., "!
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In the Matter of )
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UNITED STATES DEPARTMENT OF ENERGY )
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PROJECT MANAGE:ENT CORPORATION ) Docket No. 50-537
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TENNESSEE VALLEY AUTHORITY )
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(Clinch River Breeder Reactor Plant) ) [/ 'i
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APPLICANTS' RESPONSES TO NATURAL RESOURCES DEFENSE 1,3' Wt
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COUNCIL, INC. AND SIERRA CLUB ,x ;,e EIGHTEENTH SET OF INTERROGATORIES '
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Pursuant to 10 C.F.R. 5 2.740b. and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy and Project Management Corporation, for themselves and on behalf of the Tennessee Valley Authority (the Applicants), hereby respond to the Natural Resources Defense Council, Inc. and the Sierra Club Eighteenth Set of Interrogatories dated April 15, 1982.1/
-*/ Applicants hereby respond to all interrogatories in the Eighteenth Set except: VI, 8b. and c. (objected to); $D3 VI, 2-9 and 11 (withdrawn); I, 11 (limited by agreement; 3 se response forthcoming); IX (withdrawn); VIII (limited by
$2@ agreement; response forthcoming); VII, 1, 3, 4-5 (2 with-gg drawn; limited by agreement; response forthcoming); I, 19- /[
mo 20 and VI, 23-25 (limited by agreement; response forth-
- $ coming). Applicants have proceeded to provide these
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no responses, notwithstanding the Board's extant Protective Order, in an effort to expedite these proceedings. In
$8 providing these responses, Applicants do not concede 2< that the information is admissible in or necessary to oe a decision in the LWA proceedings. Intervenors should
@@o contact Warren Bergholz (202/252-6975) to make arrange-ments for inspection and copying of documents.
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Answers to General Questions (a) - (f)
(a) Procide 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 thereof, relied upon by Applicants, now or in the past, which serve as the basis for the answer. In lieu thereof, at Applicants' option, a copy of such document and study may be attached to the answer.
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.
ANSWER: Unless otherwise indicated below in regard to the answer under the heaing
" DOCUMENTS"; none.
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(d) Identify by name, title and affiliation the I primary Applicant employee (s) or l consultant (s) who provided the answer to the question.
l ANSWER: See the attached affidavits.
(e) Explain whether Applicants are presently engaged in or intend to engage in any further, ongoing research program which may affect Applicants' answer. This answer need be provided only in cases where Applicants 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 subject matter questioned, and state the qualifications of each such expert. This answer may be provided for each separate
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. e question or for a group of related questions. !
i This answer need not be provided until i
Applicants have in fact identified the expert (s) in question or determined that no t expert will testify, as long as such answer }
provides reasonable notice to Intervenors.
ANSWER: Applicants have not yet identified {
the expert (s) in question. f l
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-~ n-I. CONTENTIONS 1, 2. AND 3 INTERROGATORY l Is human error a significant contributor to the overall risk of accidents in:
- a. the CRBR?
- b. LMFBRs?
- c. LWRs?
RESPONSE 1 The Applicants have not quantified the contribution of, human error to the overall risk of accidents for CRBRP, LMFBRs, or LWRs. For CRBRP, the Applicants have considered human error as an important factor and included assessment of human error in the detailed design, plant operation and system interaction studies.
Since only the feasibility of reducing the liklihood of the HCDA is at issue for LWA-1, the quantification of the contribution of human error is not necessary.
SET XVIII AD _ . - - - . -
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INTERROGATORY 2 Are there any differences in the role human error plays in contributing to overall accident risk between:
- a. the CRBR and LWRs?
If the answer is yes, explain the extent of and reasons for each difference.
RESPONSE 2 The applicants have not performed analyses to compare the contribution of human error to overall risk for CRBRP, LWRs, or LMFBRs.
9 I l SET XVIII AD 1
INTERROGATORY 3 Has Applicants' position regarding the significance of human error as a contributor to the overall risk of accidents for any l reactor type changed since TMI? If the answer to this interrogatory is yes:
- a. explain in detail how Applicants' position has changed;
- b. identify and provide any and all documents related to ,
Applicants' current position.
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f RESPONSE 3 No. The Applicants have always regarded human error as a contributor to the overall risk of accidents. The events at TMI L provide additional information concerning this aspect of accident f risk but they do not cause a change in the Applicants' position. l See the response to Interrogatory 1 above.
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SET XVIII AD INTERROGATORY 4 Do Applicants agree with the statement in the report of the Reactor Safety Research Review Group (September 1981) that most studies of the likely causes of serious accidents conclude !
through probabilistic risk analysis that over 50% of the risk is '
associated with human failure to perform as intended? :
- a. If the answer to this interrogatory is yes, identify and Provide all documents in the possession of Applicants :
relating to this issue.
- b. Detail why Applicants do not agree with this statement. l RESPONSE 4 l The Applicants can neither agree nor disagree with this statement because there is no specificity regarding the terms "most studies," "likely causes," " serious accidents," and " risks." See ,
the answers to Interrogatory 1, 2 and 3 above concerning ;
quantification of human error. i i
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i SET XVIII AD l
l INTERROGATORY 5 For each of the following core disassembly scenarios, compare the relative probability of failure to shutdown between the CRBR and l the Fast Flux Test Facility: L l
- a. Loss-of-Flow (LOF); !
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- c. LOF-driven-TOP. !
RESPONSE 5 :
The Applicants have not performed analyses to compare the
. relative probability of failure to shutdown CRBRP and FFTF in response to the listed events. !
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F SET XVIII AD ___
INTERROGATORY 6 In light of the fact that the " Standard Format and Content"
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(Feb. 1974) was a preliminary document on which further work was dropped, what is the basis for believing that the 67 events identified in the " Standard Format and Content" document encompass all credible events that should be considered in establishing the design basis of the CRBR?
RESPONSE 6 The Applicants do not believe that the events identified in the
" Standard Format and Content" encompass all credible design basis events for CRBRP.
I SET KVIII AD INTERROGATORY 7 l i
Identify and provide all systems interaction studies relied upon
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by Applicants to ensure that the CRBR design is adequate to cope '
safely with potential accidents involving human error and ,
multiple system failures.
i HERPONSE 7 r
The studies which are pertinent to NRDC Contention la. are ;
identified and explained below.
e The CRBRP plant is designed to comp 3y with the requirements !
specified in 10CFR50, 10CFR100, Nuclear Regulatory Commission f Regulatory Guides and Branch Technical Positions as they relate to the application of the single failure criterion as defined in I 10CFR50, Appendix A. The plant design base is that: for any l plant condition any single failure of any active component must i be assumed in addition to the initial event. The safety, function !
must be accomplished using the off-site power source (assuming l the on-site power source to be unavailable) or using the on-site ;
power source (assuming the off-site power source to be i unavailable). The source of the failure assumptions could be due to human error or component failures. The Applicants have [
provided redundant diverse reactor shutdown and decay heat L removal paths to ensure design adequacy for these functions. The ;
Applicants cJntinually review the adequacy of the design with l respect to compliance with,the single failure criterion within !
the Quality Assurance Program defined in Chapter 17 of the PSAR. l The evaluation of the Applicants' accident analysis is provided in Chapter 15 of the PSAR. L In addition to the Applicants' safety analysis for postulated !
accidents within the design basis, the Applicants and the Nuclear -
Regulatory Commission agreed that the probability of core melt !
and disruptive accident can and must be reduced to a sufficiently i
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SET XVIII AD l 1
. . J low 1Gvel to juctify their exclusion from the dzsign basis ,
accident spectrum. CRBRP-3, " Hypothetical Core Disruptive Accident Considerations in CRBRP," discusses potential initiators of an BCDA and the design features that prevent their initiation.
Consequently, such accidents are considered to be hypothetical and are beyond the design basis. Nevertheless, structural and thermal margins beyond the design base are being included in the design as discussed in depth in the CRBRP-3 two-volume report.
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SET XVIII AD INTERROGATORY.8 Since the TMI-2 accident what specific changes (significant from a safety standpoint) have been made, and what additional changes must be made, in the design of the CRBRP to cope with potential interaction accidents involving human error and multiple system failures?
RESPONSE 8 As stated in the response to Interrogatory 7, the CRBRP design basis is in compliance with the Nuclear Regulatory Commission single failure criterion. Further, the functions necessary to prevent initiation of HCDAs have redundancy and diversity which provide capability to cope with potential interaction accidents.
The Applicants have assessed Hypothetical Core Disruptive l l
Accidents and prudent margins beyond the design basis are 1 included to provide further protection to the public health and safety. The manner in which the Applicants will address the l applicable provisions of NUREG-0718 (Licensing Requirements for Pending Applicants for Construction Permits and Manufacuring License) is set forth in PSAR Appendix H.
i SET XVIII AD f
INTERROGATORY 9 Since the TMI-2 accident what specific changes (significant from a safety standpoint) have been made, and what additional specific changes must be made, in the regulations and other criteria used to judge the adequacy of the CRBRP design and the suitability of the CRBRP site in light of the lessons learned from the TMI-2 accident and subsequent safety analyses? J RESPONSE 9 The regulations codified under Title 10 Chapter 1 of the Code of Federal Regulations (10CFR) establish the rules and criteria which are used to judge the adequacy of any nuclear plant designs. These regulations and any previous or proposed changes since March 1979 are a matter of record on which they speak for themselves. The manner in which CRBRP will meet the applicable provisions of the NRC's NUREG 0718 post-TMI requirements is set forth in the letter from J. R. Longenecker, to P S. Check, dated March 17, 1982.
SET XVIII AD ,
INTERROGATORY 10 Bave Applicants developed any responses since April 23, 1977 to the letter from Richard P. Denise to Lochlin W. Caffey, dated May 6, 1976? If the answer to this interrogatory is yes, identify and produce such responses and any and all documents in '
the possession of Applicants relating thereto. I RESPONSE 10 -
There have been no specific responses since April 23, 1977. The .
PSAR amendments which have been submitted since that time .
(Amendments 39 to 67) may include information relevant to, but not directly responding to, the letter. ,
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SET XVIII AD
. o INTERROGATORY 12 Explain in detail the justification for Applicants' statement to the ACRS on February 2, 1982 that "[f] or the electrical portions of our design, it is infeasible to a certain extent to apply some statistical meaning to the data we have gotten for our reliability tests." (Tr. p. 114).
RESPONSE 12 The Applicants' representative was misquoted in the referenced transcript. The statement actually made by Mr. Clare was: '
"for the electrical portions of our design, it is in fact feasible, to a certain extent, to apply some statistical meaning to the data..." (emphasis added)
DOCUMENTS ACRS Transcript for CRBRP Subcommittee Meeting of February 2, 1982 (P. 114)
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SET XVIII AD
- INTERROGATORY 13 With regard to limiting overpower transients and undercooled events, what trip settings are relied upon to ensure that the following categories of events are accommodated within the design basis (i.e., the damage severity limits)?
- a. anticipated events;
- b. unlikely events;
- c. extremely unlikely events.
DERPONSE 13 The Project has analyzed anticipated, unlikely, and extremely
. unlikely overpower and undercooling transients. The protective subsystem respor.3es to these off-normal transients are event dependent.
A listing of the off-normal transients for which each protective subsystem responds is provided in PSAR Section 7.2. Analysis of the plant's responce to limiting overpower and undercooling transients is provided in PSAR Sections 15.2 and 15.3, respectively.
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SET XVIII AD i -.
INTERROGATORY 14 Explain in detail how and when the various trip settings and trip bypasses are set in order to scram the primary and secondary control rod systems, including whether they are set manually.
RESPONSE 14 The trip and bypass settings are caJibrated in place by replacing the sensor with a calibrated test signal generator. The output of the signal generator is adjusted to set the instrument channel output at the desired trip or bypass level. The setpoints are then manually adjusted until the logic output switches from a
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reset to a trip condition. The setpoint adjustment is then locked in place. Following adjustment of the'setpoint, proper operation is verified by perf ormin'gf a functional' test of the
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unit. This consists of inserting' test cignals into the chsnnel to challenge the unit to perf orm the trip / bypass f unc$ ion.
Initial setpoint calibration occurs after initial installation in the plant, but prior to the preoperational test period. Proper calibration of trip / bypass setpoints is verified during preoperational testing. There is no setpoint adjustment ^ required during reactor operation. Trip setpoints are recalibrated during each refueling period with the calibration period not exceeding 18 months, s
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SET XVIII. AD ,
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- INTERROGATORY 15 Is it possible that the various trip settings and trip bypasses used to scram the primary and secondary control rod systems could be set erroneously due to human error?
RESPONSE 15 Setpoint calibrations are independently verified for acceptable operation. Functional testing is periodically performed to verify correct trip / bypass operation at the required level.
Measurements made during calibration are recorded to allow independent review and verification of correct setpoint values.
With the checks and cross checks performed during calibration and the subsequent functional tests to verify correct operation, the likelihood that human error will lead to erroneous setpoints is minimized.
h SET XVIII AD - _ - _ _ _ _ _ _ _ _ _ _
INTERROGATORY 16 Identify precisely upon which portions, in whole or in part, of the PSAR and other documents (including but not 1.imited to CRBRP-1, CRBRP-2, CRBRP-3, CRBRP-GEFR-00523, WARD-D-Oll8, NEDM-14082) Applicants intend to rely at the LWA-1 stage in order to demonstrate
- a. that the CDA should be excluded from the design basis; and
- b. that the source term selected for CRBR is suitably conservative for purposes of Part 100.
RESPONSE 16 It is the intent of the Applicants to rely on portions of the PSAR, CRBRP-3, CRBRP-GEFR-00103, and CRBRP-GEFR-00523, to demonstrate both a) and b). The precise extent, by selected content, to which these documents will be relied on for the LWA has not been determined. The Applicants will update this response at such time as this or additional documents are idantified. The Applicants do not currently plan to rely on any portions of CRBRP-1 or CRBRP-2.
SET XVIII AD !
INTERROGATORY 17 Will Applicants rely on, discuss, cite or otherwise use in any way probabilistic analyses of CRBRP accident risks and/or consequences in. preparing and/or presenting its case in the CRBRP LWA-1 proceeding? If the answer is "yes" describe how such analyses will be used and identify them and provide them if they have not previously been provided.
RESPONSE 17 The Applicants do not plan to rely on the report CRBRP Safety Assessment (CRBRP-1), as stated in the response to Interrogatory 16 above. The precise extent to which the Applicants will " rely on, discuss, cite or otherwise use in any way probabilistic analyses of CRBR accident risks and/or consequences in preparing and/or presenting its case in the CRBRP LWA-1 proceeding" cannot be specified at this time, l
I SET XVIII AD --
INTERROGATORY 18 '
Explain why Applicants decided to withdraw the so-called
" parallel design" (original Appendix F to the PSAR)?
RESPONSE 18 '
I The reasons for the Applicants' withdrawal of the parallel design ;
are found in the following documents:
(1) The Project's April 30, 1976 letter to the NRC transmitting Amendment 18 to the PSAR (particularly paragraph 4),
(2) The NRC's May 6, 1976 letter to the Project (particularly h the penultimate paragraph), and (3) The Proj ect's July 22, 1976 letter to the NRC transmitting Amendment 24 to the PSAR (particularly paragraphs 2 and 3).
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i SET XVIII AD II. CONTENTION 2 INTERROGATORY l ;
For each of the following three core disassembly scenarios, identify the six most important parameters or assumptions under- ;
lying such scenarios (e.g., location of failure) in terms of their potential impact on energetics and the CRBR's capability to !
accommodate such energetics (keeping in mind the uncertainties in our knowledge): '
- a. loss-of-Flow (LOF) ;
- c. LOF-driven-TOP.
RESPONSE 1 i
The interrogatory mistakenly identifies the LOF-driven-TOP as an HCDA scenario. The Applicants have used the term LOF-driven-TOP .
in reference to a specific type of fuel failure phenomenology or !
core condition that may occur in selected LOF-HCDA scenarios. It would therefore be misleading to answer part c. of this interrogatory in the same context of parts a. and b.
Analyses of the important parameters or assumptions is dependent on the particular analysis case. CRBRP-GEFR-00523 discusses the ;
important assumptions and parameters case-by-case. We have '
selected the best estimate cases from CRBRP-GEFR-00523 and listed several of the most important parameters and assumptions in Table II-1.1. CRBRP-GEFR-00523 should be referred to for a full discussion of the important parameters and assumptions in all cases.
i SET XVIII AD l-
Table II-1.1 Six Most Important Parameters or Assumptions in LOF and TOP HCDAs Best Ertimate Best Estimate TOP Best Estimate LOF BOC-1 & EOC-4 BOC-1 & EOC-4 o Failure to scram o Failure to scram o Doppler coefficient o Dopper coefficient o Initiating ramp rate o Core orifice pattern
- o Fuel reactivity worth o Fuel retained fission gas assumptions **
o Fuel Failure location ** o Fuel vapor pressure parameters o Core orifice pattern
- o Fuel-steel dispersive boiling o Initial power level o Fuel reactivity worth o Post fuel failure assumption o Sodium void worth o Fuel pin penetration into gap geometry l
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- Channel to channel differences in power-to-flow ratio. l
- A single assumption or several assumptions concerning parameters and parameters and models related to phenomenon.
SET XVIII AD i I
INTERROGATORY 2 L
Identify each CRBR component with a potential impact on the capability of CRBR to accommodate a CDA, whose design or other aspect has been changed since April 23, 1977.
- a. For each component identified above, explain in detail the impact of such change on the potential consequences of a CDA.
RESPONSE 2 The CRBR core has been changed from a homogeneous design to a heterogeneous design as described in Amendment 51 to the PSAR.
The effect of the heterogeneous core on HCDA energetics is .
assessed in CRBRP-GEFR-00523. In addition, this assessment has !
been incorporated in CRBRP-3, Volume 1, Section 4.0. !
l The only significant change that affects the Structural Margin Beyond the Design Base (SMBDB) assessment is a change to the Reactor Vessel Support System described in Section 3.8.3.1.1 of :
the PSAR. The impact of this design change has been analyzed in >
detail and the complete results were incorporated into the CRBRP-3, Volume 1 in Revision 3 (Section 5 and Appendix B). ;
The plant ~ components (design features) which are used to provide [
Thermal Margin Beyond the Design Base (TMBDB) are described in l CRBRP-3, Volume 2, Section 2.2. The impacts of these features are described in Section 3 (Thermal) and Section 4 (Radiological) of CRBRP-3, Volume 2.
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SET XVIII AD
. o INTERROGATORY 3 Identify all currently utilized codes and subroutines of codes I Presently employed by Applicants in analyzing CDAs and their consequences.
- a. Indicate which of the codes identified above have been employed by Applicants for the first time since April 23, 1977;
- b. Indicate which of the subroutines of codes indicated above have been employed by Applicants for the first time since April 23, 1977;
- c. Identify which of the codes indicated above have been changed since April 23, 1977;
- d. Indicate which of the subroutines of codes indicated above have been changed since April 23, 1977.
RESPONSE 3 The attached table identifies computer codes used in the detailed analysis of BCDAs and their consequences. The table identifies references for the user guide or manual for each computer code.
The subroutines for these codes are identified in the descriptive documentation identified in updated responses to interrogatories SET II (responses I(A)1, I(B)1, and I(C)1), SET III (response 1(B)l), SET V (responses I(A)1, I(B)1), SET, VI (responses I(A)l, l I(B)l, I(C)l) and in computer code documentation references identified in the attached table.
- a. The only code which has been applied by the Applicants for the first time since april 23, 1977 is PLUTO-2.
SET XVIII AD __
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- b. Tha cubroutinue in PLUTO-2 cre the only cubroutines that have been applied for the first time since April 23, 1977.
- c. The SAS3D code currently being used by the Applicants has been changed since April 23, 1977 to incorporate application of SASBLOK and the revisions described in Section 3.2.3 of CRBRP-GEFR-00523.
- d. Only those subroutines of SAS3D affected by the changes ;
indicated in part c. have been revised since April 23, 1977.
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COMPUTER CODES USED IN THE ASSESSMENT OF HCDA CONSEQUENCES i
Comouter Code Reference i
ANSYS PSAR Page A-5 !
CACECO PSAR Page A-12 COMRADEX-III PSAR Page A-19, Reference 1 HAA-3B PSAR page A-140, Reference 1 PIFITE CRBRP-3, Volume 1, Page C-1 ;
PLUTO 2 CRBRP-GEFR-00523, Page 11-3, Reference 25 REXCO-HEP CRBRP-3, Volume 1, Page C-3 :
SAS3A & 3D CRBRP-3, Volume 1, Page C-4, References 1&2 (Including SASBLOK) * '
TRANSWRAP PSAR Page A-252 -
TRUMP PSAR Page A-256 '
VARR-II PSAR Page A-258, Reference 1 VENUS-II* CRBRP-3, Volume 1, Page C-4 WECAN PSAR Page A-263, Reference 2
- The nuclear input parameters for these codes are processed using the methods and nuclear data files identified in Section 4.3 of the PSAR. '
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SET XVIII AD l
i DC5:RROGATORY 4 Are Applicants relying or intending to rely for the LWA-1 upon l any documents other than the PSAR and documents ref erenced therin in support of their assertion that CDAs need not be treated as DBAs? If the answer to this interrogatory is yes, identify and Provide all such documents and any and all such documents in the ;
Possession of Applicants related thereto. Answer the same ;
question with respect to the construction permit.
RESPONSE 4 Refer to answer to Interrogatory 16 for Contentions 1, 2, and 3 (above).
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l, SET XVIII AD l
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INTERROGATORY 5 In light of the TMI accident, to what extent is the CRBR design adequate with respect to its capability to remove core material from the reactor following a CDA and reactor vessel rupture?
RESPONSE 5 The Applicants have not performed analyses to assess this capability.
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SET XVIII AD .. . .- .
l III. CONTENTIONS 4 AND $ (B) (4) i INTERROGATORY l ,
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Since April 25, 1977, have Applicants prepared or received any documents which discuss: I
- a. the costs of safeguards and physical security at the CRBR and supporting fuel cycle facilities; I l
- b. the risks and consequences of safeguards and/or physical f security failure at the CRBR and supporting fuel cycle facilities; l
- c. the nature and scope of the current threat from terrorists, saboteurs, and thieves to the CRBR and supporting fuel cycle facilities; and/or I
- d. 'the nature and scope of projected, future threats from i terrorists, saboteurs, and thieves to the CRBR and supporting i fuel cycle facilities? i 1
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If the answer to any part of this interrogatory is yes, identify l P
and produce such documents.
RESPONSE 1 i i
- a. (1) With regard to CRBR.
Yes, for Radiological Security (formerly Physical ;
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SET XVIII AD .
DOCUMENT LIST SAFEGUARDS RETRIEVAL INFORMATION 73.21 DOCUMENT I.D. DATE JES HQ ECP B10-005, Rev. O BD70567 06/09/77 X ECP B10-005, Rev. 1 BD80415 05/15/78 X DOE Approval of B10-005, EN:CM:78-198 07/19/78 X Rev. 1 Semi-Annual Cost Review BD0ll47 09/03/78 X Semi-Annual Cost Review BD10484 04/09/81 X Agenda Semi-Annual Cost Review BD10746 06/05/81 X ECP B18-009 EN:CM:81-219 09/21/81 X Study, Security Facilities 18.AA-7-001 01/25/81 X Award Approval PR:81-184 02/25/81 X Award Contract Transmittal BD10198 05/03/81 X Proposal - Johnson N/A 06/30/81 X Proposal - VT N/A 07/01/80 X Proposal - Diamond N/A 07/01/80 X Proposal - Sygnetron N/A 06/30/80 X i B&F - Johnson N/A 10/30/80 X B&F - VT N/A 10/27/80 X B&F - Diamond N/A 10/30/80 X B&F Sygnetron N/A 06/30/80 X Fair Cost Estimate PO:084-80 01/17/80 X Purchase REQ P3066-1291 02/25/80 X Purchase REQ P3066-1520 02/25/81 X Purchase REQ P3066-1291, 11/11/81 X Rev. 1 J Contract Waiver Requests Transmittal 09/06/81 X
- 33 CNRs to Project Office BD11153 09/09/81 X CWRs to Sygnetron BZ10939 10/13/81 X Return CWRs to Burns N/A 11/16/81 X and Roe from'Sygnetron Telefax (from Sygnetron) N/A 04/15/82 X Contract Amendment BZ20410 03/30/82 X l
SET XVIII -
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- e. (2) With Rsgard to the Fuel Cycle.
Yes DQQJMENTS LIST (a) " Safeguarding a Mixed-Oxide Industry Against A Hypothetical Subnational Threat," NUREG 0414, May 1978.
(b) Letter from John R. Longenecker (DOE)
Paul S. Check (NRC) of March 24, 1982 w/ enclosure entitled "G. Safeguards Costs."
- b. (1) With Regard to CRBR. Yes, for Radiological Security.
DOCUMENTS LIST (a) Sabotage Target Identification for CRBRP - SAND 77-1728 - N. ORTIZ Printed 6-81 (Secret N.S.I.)
(b) CRBRP Sabotage Analysis - SAI-C-23-PA, May '79, L. Ryes (Confidential, N.S.I)
- b. (2) With Regard to the Fuel Cycle.
No documentation with regard to DRP and SAF.
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- c. The Applicants have no such documentation.
- d. The Applicants have no such documentation.
SET XVIII AD _ _ _ _ _ _ _ _ _ _ _
INTERROGATORY 2 Since April 25, 1977, have Applicants prepared or received any documents which discuss the possibility that an act of sabotage or terrorism could be a CDA initiator at the CRBR? If the answer to this Interrogatory is yes, identify and produce such documents.
RERPONSE 2 Yes. Duplicates list 1.b above.
I SET XVIII AD l '
INTERROGATORY 3
- a. State what specific measures have been adopted since April 25, 1977, to improve safeguards and physical security at the CRBR and supporting fuel cycle facilities;
- b. For each such measure, specify (i) its cost, (ii) the reasons for its adoption.
RESPONSE 3
- a. (1) For CRBR. Prior to April 25, 1977, there was no defined ,
Radiological Security System. Since then the System, described in System Design Description (SDD) 18, has been refined by an iterative process in response to Plant changes and analysis done to evaluate the security I system per se.
(2) For the Fuel Cycle. The criteria for and the safeguards / security " measures" implemented (and being implemented for new facilities) at DOE facilities which Probably will fabricate mixed-oxide fuel for the CRBRP (and for other purposes) were established prior to April 15, 1977.
- b. (1) For CRBR. See Table " CHANGES TO THE SYSTEM SINCE B10-005 (THE ECP WHICH CREATED SDD 18)" I t
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EET XVIII AD I
l CHANGES TO THE SYSTEM SINCE B10-005 (THE ECP WHICH CREATED SDD 18)
Change Reason Cost Added card reader It was possible to go from non-vital $5,000 and TV camera to to vital area without clearance, elevator in Con-trol Building. !
Moved Door to Old location of door permitted too many Drawing enter Control people into Control Room in order to Change Room and its see plant supervisor. only associated card reader.
Added thre'e Result of analysis which showed $4,500 card readers weakness, in Cell 271.
Changed exterior Increased system reliability and Saving of sensor from E E field was mcre labor intensive in $115,000 ;
field to micro- installation and less reliable in wave. As part performance. The original TV pole '
of the same proved more expensive and less change, type of stable than requirements dictated.
TV support poles were changed. .
i, SET XVIII AD _
- b. (2) Fcr the fusi cycle.
Not applicable.
t i
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SET XVIII AD I
INTERROGATORY 4
- a. State what alternatives to the planned safeguards and physical security systems at the CRBR and supporting fuel cycle facilities are currently under consideration.
- b. For each alternative stated, specify (i) its cost, and (ii) the reasons which would support its adoption.
RERPONSE 4
- a. There are no alternatives being considered for the Safeguards Systems at this time. !
- b. N/A.
i t
r p
b h
f SET XVIII AD INTERROGATORY 5 Specify the ways, if any, that the threat to the CRBRP and supporting fuel cycle facilities has changed since April 25, 1977.
RERPONSE 5 No change. Threat studies performed since April 25, 1977 have shed additional light on the nature and capability of terrorists, but not on the probability of the threat per se.
O e
l l
, SET XVIII AD l
lb, CONTENTION 5 INTERROGATORY l Provide the information requested below for each rf the following facilities:
- a. Oak Ridge National Laboratory;
- b. Y-12 Plant;
- c. K-25 Plant (Oak Ridge Gaseous Dif fusion Plant):
(1) Describe the national security function (s), if any, performed at each facility.
(2) If an evacuation of such a facility were required, how many people would be required to remain at each facility for national security, or other reasons if the dose to such people were likely to reach:
(a) 1 rem; (b) 5 rems; (c) 25 rems; (d) 100 rems; (e) 250 rems; (f) 500 rems.
l SET XVIII AD .
(3) Idantify fully the national =ecurity impact, if cny, of losing access to each facility:
(a) for one week; (b) for one month; (c) for three months; (d) for six months; (e) for one year; (f) indefinitely.
RESPONSE 1 (1) The Oak Ridge National Laboratory is a research and develop-ment facility with no national security activities.
The Oak Ridge Gaseous Diffusion Plant (ORGDP) enriches uranium in the isotope U-235, up to 4.0% hasay, almost exclusively for commercial nuclear power reactors. In addition to these production activities, significant development work is conducted on advanced isotope separation f technologies. Development of these technologies is also intended for meeting future enriched uranium requirements for power reactors. In our opinion, no functions are conducted at the ORGDP which can be construed as affecting national security.
The Oak Ridge Y-12 Plant is a major facility within the Department of Energy's (DOE) nuclear weapons production complex. The Plant produces components and subassemblies in l l
i 9
SET XVIII AD _ - _ _ _ _ _ _ _ _ _ _ _ _
i , ,
support of the production of nuclear weapons delivered by
! DOE to the Department of Defense. The Plant also produces components used in the nuclear weapons development and testing programs carried out by the three DOE nuclear, weapons design laboratories.
(2) We have not done the analysis for the specific dose levels indicated. We have completed an analysis for the SSST (see response to Interrogatory 3 below). In the event of a release of radionuclides in a range that would require l
evacuation of all but essential personnel, the numbers of personnel likely to remain on-site would be as follows:
i ORNL -
60 ORGDP -
65 Y-12 Plant -
250 (3) .The Applicants have not done detailed analyses of the national security impact of losing access to each facility for long term durations of time. Since the Y-12 Plant is the only facility of the three specified that performs
, national security activities, this question does not apply to ORNL or the ORGDP.
The Y-12 Plant is located approximately ten miles from the CRBR. At this distance it can be inferred from the radiation dose data graphed for the SSST (see attachment) that the projected radiation doses received af ter reentry only a few hours af ter the release would be well within occupational standards and no evacuation would be required.
. The impact of the SSST accident scenario on Y-12 Plant operations would be insignificant in regard to DOE's ability to meet its national security commitments.
I l
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l SET XVIII AD .
- _ . . _ _ _..-,,,e _ _ _ . - .
l (b) Dose data for SSST accident attached.
I (c) NA (d) H. W. Bibbitts, Emergency Preparedness Director, USDOE, OR l (e) NA (f) -
i SET XVIII AD ._ .. . - _ _ . . . - . _ - _ -
c i
V. CONTENTION 6 i INTERROGATORY l
[
i Identify each fuel cycle facility (including fuel production, i storage, preparation, fabrication, reprocessing, spent fuel l storage, and waste disposal facilities) that (a) is likely to be i used; or (b) may be used in the a CRBR fuel cycle throughout its !
entire operating life. [
. I RESPONSE 1 l l
- a. The CRBRP fuel cycle facilities most likely to be used are ,
identified in letter, J. R. Longenecker to P. S. Check, l "CRBRP Fuel Cycle," dated March 19, 1982.
- b. The Applicants can't speculate about what fuel cycle facilities, other than those identified in part a., may be f
used.
DOCUMENTS As indicated in response.
b 9
b I
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f 1
l SET XVIII AD l
l INTERROGATORY 2 Indicate whether staff takes the position that the following regulations apply to each of the facilities identified in response to Interrogatory 1 above:
- a. 10 CFR Section 50.34(c);
- b. 1) CFR Part 20; ,
- c. 10 CFR Part 60;
- d. 10 CFR Part 70; i
1 f.- 10 CFR Part 73.
RESPONSE 2 The Applicants' do not know the Staff's position regarding I applicable regulations. It is the Applicants' position that the indicated regulations will apply, where applicable, to the fuel cycle facilities which are licensed by the NRC, as indicated in the following table.
CRBRP Fuel Cycle Facilities NRC Licensed DDE 1
Blanket Fabrication Facility Secure Automated Fabrication Facility CRBRP Developmental Reprocessing Plant Low-Level Waste Disposal Transuranic Waste Storage Facility Facility SET XVIII AD - _ _ _ _ _ _ _ _ _ _ _ _ _ _
h n
.o NRC Licensed gg3 Transuranic and.High-Level PUO 2 Conversion Facility WaNte Respository 308 Building, Hanford, Washington s
Regarding the Applicants' facilities excluded from the NRC's licensing jurisdiction existing f Departmental Orders equivalent to or more restrictive than the NRC regulations shall take primacy in complying with the requirements to make every reasonable effort to maintain _ radiation exposures, and releases of radioactive mate' rials in effluents to unrestricted areas, as low as is reasonable achievable.
DOCUMENLS Letter d. R. Longenecker to P. S. Check, "CRBRP Fuel Cycle,"
dated March 19, 1992.-
l SET XVIII AD . l
l INTERROfaAIQRX_1 For each of the facilities and regulations in Interrogatory 1 and j 2 above, if Applicants' response is that a specific regulation on a particular subject does not apply to a facility, indicate which regulation (s) on that subject do apply to such facility and specify each and every difference in the regdlations.
RESPONSE 3 The DOE facilities exempt from NRC licensing in Response 2 will be subject to applicable DOE Orders or related directives including:
DQE Order Subiect 5440.lA Implementation of the National Environmental Policy Act 5480.1 and 1A Environmental Protection, Safety and Health Protection Program for DOE Operations chapter I Environmental Protection, Safety and Health Protection Standards Chapter III Safety Requirements for the Packaging of Fisaile 'and Other Radioactive Materials Chapter IV Nuclear Criticaliity Safety Chapter V Safety of Nuclear Facilities Chapter VI Safety of Department of Energy Owned Reactors Chapter VII Fire Protection SET XVIII AD l
DQE Order Subiect Chapter VIII Contractor Occupational Medical Program Chapter IX Construction Safety and Health Programs Chapter X Industrial Health Program Chapter XI Requirements for Radiation Protection Chapter XII Prevention, Control and Abatement of Environmental Pollution Chapter XIII Aviation Safety 5481.lA Safety Analysis and Review System 5482.lA Environmental Protection, Safety, and Health Protection Appraisal Program
.5483.1 Occupational Safety and Health Program for Government-Owned Contractor-Operated Facilitier 5484.1 Environmental Protection, Safety and Health Protection Information Reporting Requirements 5484.2 Unusual Occurrence Reporting System 5500.1 Vital Records Protection Program 5500.2 Emergency Planning, Preparedness and Response for Operations i
l l
SET XVIII AD . _ - _ _ _ . _ .
l
DQE Orders subject 5500.3 Reactor and Nonreactor Nuclear Facility Emergency Planning. Preparedness and
Response
5500.4 Public Affairs Policy and Planning Require-ments for Emergencies 5700.6A Quality Assurance The differences between the regulations cited in Interrogatory 2 and the applibable DOE Orders speak for themselves.
DOCUMENTS As indicated in response.
SETXVIII AD - - .
INTEREDGATORY 4 1
Identify each principal environmental impact associated with the operation of any of the following DOE reprocessing plants that may be used to supply fuel for the CRBRP fuel and compare it to the projected impact (if any) of the model reprocessing plan,t discussed in WASH-1535 and the Draf t Supplement EIS (DOE /EIS- j 0085-D): l
- a. the Savannah River Plant (H Canyon);
- b. the Savannah River Plant (F Canyon);
- c. the Idaho National Engineering Laboratory; and
- d. the Hanford PUREX Plant.
RESPONSE 4 The Hanford PUREX plant is considered the most likely facility for supplying fuel for the CRBRP. The specific principal environmental impacts associated with operation of the Hanford PUREX plant to supply fuel for the CRBRP have not been estimated.
However, the overall environmental impact associated with PUREX operation including operation to supply fuel for CRBRP, is being developed and will be available later this year in a Draf t Environmental Impact Statement (DEIS). Notice of the PUREX DEIS availability will be published in the Federal Register. A comparison with WASH-1535 and DOE /EIS-0085-D has not been made.
1 i
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SET XVIII AD .__
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INTERROGATORY 5 i
For each of the facilities' listed in Interrogatory 4 above, I identify, for each of the last five years (or, for the Hanford PUREX plant, the five years prior to its shutdown), the principal ;
radioactive releases (curies of each isotope) from such facility to:
4
)
- a. the atmosphere; and
- b. liquid effluent streams. 4
, RESPONSE 5 i i
The most recent five years of operation for the Hanford PUREX f plant are 1968 through 1972. Gaseous and liquid effluent releases from PUREX during these years is included in annual [
reports on the environmental monitoring of Hanford site ;
activites. References for the years 1968 through 1972 are:
- 1. Evaluation of Radiological Conditions in the Vicinity of Hanford for 1968, BNWL-1341, May 1970.
- 2. Evaluation of Radiological Conditions in the Vicinity of Hanford for 1969, BNWL-1505, November 1970.
- 3. Environmental Surveillance at Hanford for CY.1970, J. P. Corley, BNWL-1669, September 1973.
- 4. Environmental Monitoring at Major U. S. Atomic Energy Commission Contractor Sites, Calendar Year 1971.
- 5. Environmental Monitoring At Major U. S. Atomic Energy >
Commission Contractor Sites, Calendar Year 1972, WASH 1259.
i l
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I SET XVIII AD '
INTERROGATORY 6 How and where will the following materials be disposed of:
- a. CRBRP spent fuel;
- b. high-level waste from the reprocessing of CRBR fuel;
- c. high-level waste f rom the reprocessing of LWR fuel to recover Plutonium for the CRBRP. ,
RESPONSE 6
- a. CRBRP spent fuel is expected to be reprocessed, not disposed of.
- b. In an appropriate form in a to be determined Federal repository.
- c. In an appropriate form in a to be determined Federal repository.
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- SET XVIII AD (
. o INTERROGATORY 7 6
Do Applicants take the position that they must meet the provi- i sions of 10CFR Part 71 with respect to the transportation of ;
materials in the CRBRP fuel cycle? -
- a. If the answer is no, will Applicants meet those requirements i anyway? ;
- b. If Applicants take the position that 10 CFR Part 71 is not
{
applicable, indicate which regulations Applicants claim are applicable to the transportation of materials in the CRBRP fuel cycle.
RESPONSE 7 l The transportation of materials in the CRBRP fuel cycle will l comply with, or provide, safety measures equal to or greater than !
those prescribed by 10 CFR Part 71. ;
l DOCUMENTS ,
r i
t SET XVIII AD INTERROGATORY 9 Will the disposal of wastes generated from the CRBR spent f uel, including high-level wastes from processing
- a. be subjected to:
- i. NRC jurisdiction?
- 11. EPA jurisdiction?
- b. be classified as defense waste?
- c. be classified as commercial waste?
RESPONSE 9
- a. i. Yes.
ii. Yes.
- b. No.
- c. Yes.
DOCUMENTS I None.
SET XVIII AD VI. CONTENTION 7 INTERROGATORY l Identify the precise criteria, if any exist, which must be met l
for the CRBR to meet each of its programmatic objectives.
RESPONSE 1 The major programmatic objectives of the CRBRP as stated in the LMFBR Program FES (ERDA 1535) are:
o to demonstrate the technical performance, reliability, maintainability, safety, environmental acceptability, and economic feasibility of an LMFBR central station electric powerplant in a utility environment.
o to confirm the value of this concept for conserving important nonrenewable natural resources.
The criteria against which the CRBRP will be measured to determine if these objectives are met include:
Technical Performance--CRBRP will be designed, constructed, tested, and operated to achieve the project's technical parameters. Examples of these parameters are plant thermal power Production, net electric power production, and steam conditions.
Reliability--The CRBRP is being designed to function as a i baseload unit, for which is generally accepted to mean that it will be available between 60 and 90 percent of the time. The CRBRP has been designed with an objective of reaching baseload reliability within the 5 year demonstration period.
l SET XVIII AD Maintainability--Th3 CRBRP will demonstrate the ability to perform corrective and preventative maintenance with a minimum ,
impact on plant availability, minimum manpower expenditure, and maximum protection of personnel. Adequate personnel protection will be demonstrated by meeting the applicable standards. Plant '
availability will be measured by the ability to parform main-tenance operations on a schedule to support operation of CRBRP as a baseload unit. t safetv--The demonstration of the safety of CRBRP will be achieved when the plant is licensed and operated within the limitations of i
NRC's requirements.
Environmental AcceDtability--The demonstration of achievement of .
CRBRP's environmental acceptability will be the plant's ability to operate in conformance with applicable federal and state ;
environmental regulations.
Economic Feasibility--The economic feasibility objective will be i demonstrated by utilizing the actual costs of designing, con-structing and operating the CRBRP to est~ablish that it is l l
feasible to expect that the capital LMFBR could be extrapolated to commercial size central station powerplants.
The objective for demonstrating these objectives in a utility environment will be met when CRBRP is operated on the TVA system, supplying power to that utility grid, by personnel of a utility, and within the normal system of that utility.
Conservatio7 of Nonrenewable Resources--The objective to confirm the value of the LMFBR in conserving important nonrenewable natural resources will be demonstrated by CRBRP's ability to generate electricity utilizing indigenous U.S. uranium resources including the otherwise unused U-238.
l SET XVIII AD !
Documents As indicated in the response.
i i
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I SET XVIII AD
. S INTERROGATORY 10 Has the value of the LMFBR for conserving important nonrenewable natural resources (i.e., uranium) been confirmed? If the answer is other than yes, explain in detail why this value of the LMFBR has not been confirmed and what would be necessary for such a confirmation.
RESPONSE 10 No. One of the objectives of CRBRP is to confirra the value of this concept for conserving important nonrenewable natural resources. As explained in response (1), to meet this obj ective the CRBRP must be designed, sonstructed, and operated and thereby generate electricity within all other constraints.
DOCUMENTS None.
e SET XVIII 'AD INTERROGATORY 12 Could the technical performance of the CRBRP be demonstrated if for any reason the plant could not operate:
- a. at all;
- b. for more than 1 year;
- c. for more than 2 years;
- d. for more than 3 years?
- e. for more than 5 years.
RESPONSE 12 The Applicants intend to complete the CRBRP demonstrations (i.e.
design, construction, and operation for 5 years). Applicants have not done the analysis, and cannot speculate about their ability to meet the project objectives in the event that this demonstration is not completed.
DOCUMENTS None.
t e
d I I l SET XVIII AD INTERROGATORY 13 Could the reliability of the CRBRP be demonstrated if for any reason the plant could not operate:
- a. at all;
- b. for more than 1 year;
- c. for more than 2 years;
- d. for more than 3 years?
- e. for more than 5 years.
RESPONSE 13 See response to Interrogatory 12.
SET XVIII AD INTERROGATORY 14 Could the maintainability of the CRBRP be demonstrated if for any
, reason the plant could not operate:
- a. at all;
- b. for more than 1 year;
- c. for more than 2 years;
- d. for more than 3 years;
- e. for more than 5 years?
RESPONSE 14 See response to Interrogatory 12.
l SET XVIII AD i l
INTERROGATORY 15 t
Could the safety of the CRBR be demonstrated if for any reason !
the plant could not operate:
- a. at all;
- b. for more than 1 year;
- c. for more than 2 years; I
- d. for more than 3 years; r
- e. for more than 5 years? ,
RESPONSE 15 i eee re.,o..e to I.terroeaeory 12. ;
I s
j SET XVIII AD l l , _
l INTERROGATORY 16 !
i Could the environmental acceptability of the CRBRP be ,
demonstrated if for any reason the plant could not operate?
i a.
at all;
- b. for more than 1 year; i
- c. for more than 2 years; ,
- d. for more than 3 years; -
i
- e. for more than 5 years.
i 5
EESPONSE 16 f
i See response to Interrogatory 12.
i
! i T
l SET XVIII AD 1
. o INTERROGATORY 17 Could the economic feasibility of the CRBRP be demonstrated if for any re'. son the plant could not operate: l
- a. at all;
- b. for more than 1 years
- c. for more than 2 years;
- d. for more than 3 years;
- e. for more than 5 years.
RERPONSE 17 See response to Interrogatory 12.
I l
SET XVIII AD 1 l
l
INTERROGATORY 18 How much would the CRBR have to cost, or what factors would have to occur, before the project would be unable to demonstrate the economic feasibility of an LMFBR central station electric powerplant in a utility environment?
RESPONSE 18 The Applicants have not done the analysis and cannot speculate as to how much the CRBRP would have to cost, or what factors would have to occur, before the project would be unable to demonstrate the economic feasibility of an LMFBR central station electric Powerplant in a utility environment. See also response to Interrogatory 12.
DOCUMENTS None.
f l
l SET XVIII AD i
INTERROGATORY 19 Indicate whether Applicants would likely drop their commitment to the Project if the following design changes were required by Staff:
- a. inclusion of a core catcher;
- b. complete prohibition of venting of the containment building;
- c. requirement that the reactor be able to contain energetic energy exceeding:
- 1. 661 megajoules; ii. 1200 megajoules; iii. 2400 megajoules; iv. 5000 megajoules;
- v. 10,000 megajoules.
- d. any combination of the design changes indicated above.
RESPONSE 19 The Applicants have not done the analysis and have not determined whether they would likely drop their commitment to the project if the indicated changes were required by Staff. The CRBRP is being designed to meet the applicable NRC requirements, and Applicante are not aware of any changes to these requirements which would render CRBRP impracticable.
DOCUMENTS None.
SET XVIII AD .
. . 1 INTERROGATORY 20 Indicate whether Applicants would likely drop their commitment to l the project if it appeared that the CP could not be granted before !
- a. 1983;
- b. 1984;
- c. 1985;
- d. 1986;
- e. 1987;
- f. 1988; ,
- g. 1989;
- h. 1990;
- i. other (specify).
RESPONSE 20 See response to Interrogatories 12 and 19 above. j i
l l
SET XVIII AD :
I s l INTERROGATORY 21 !
Does the timing obj ective (as expeditiously as possible) carry !
the same weight as other objectives of the CRBRP, e.g., utility participation? If not, please explain. -
RRRPONSE 21 The Applicants have no formula for determining the relative impot tance of CRBRP objectives. All of the CRBRP objectives are important and none are in conflict, including the timing objective.
DOCUMENTS None.
t i
SET XVIII AD .
! i l
l INTERROGATORY 22
- Indicate whether Applicants believe the CRBRP can meet its timing I
objective (as expeditiously as possible) if, because of Applicants' failure to submit an adequate design or supporting i documentation to the NRC, a CP could not be granted before:
I
- a. 1983; ;
- b. 1984; ;
i
- c. 1985; i
- d. 1986;
- e. 1987; \
- f. 1988; i
- g. 1989; i
- h. 1990; j f
- 1. other (specify).
RESPONSE 22 (a-b) The current NRC schedule projects construction permit ,
award for CRBRP in June 1984.
~
This is clearly consistent with CRBRP's timing obj ective, f
(c-1) The Applicants have not done the analysis and cannot '
speculate about the ability of CRBRP to meet its l objectives in the event that the Applicants would cause the current CP schedule to change. '
O SET XVIII AD
. e DOCUMENTS NRC memorandum, P. S. Check to H. R. Denton, dated October 13, 1981.
9 SET XVIII AD .
s l
VI. CONTENTION 8 INTERROGATORY l Have any analyses been undertaken of neutron activation products which Applicants Tely upon to determine:
- a. the potential isolation period of the CRBR following decommissioning?
- b. the economic costs of decommissioning the CRLR?
- c. the environmental costs of decommissioning the CRBR?
- d. the societal costs of decommissioning the CRBR?
If the answer to any part of this interrogatory is yes, identify and produce such assessments and any and all documents in the possession of Applicants relating thereto.
RESPONSE 1
- a. No analyses have been undertaken of neutron activation products to specifically determine the potential isolation ,
period of the CRBR following decommissioning.
- b. No analyses have been undertaken of neutron activation products to specifically determine the economic costs of decommissioning the CRBR.
- c. No analysee have been undertaken of neutron activation products to specifically determine the environmental costs of ,
decommissioning the CRBR. ,
l
- d. No analyses have been undertaken of neutron activation products to specifically determine the societal costs of ;
decommissioning the CRBR. l l
( SET XVIII AD 1 I l
INTERRDGATORi" 2 If the answer to any part of the above interrogatory is that !
Applicants do not rely on any analyses of neutron activation f products, explain in detail why Applicants believe that reliance on such analyses is unnecessary. j RESPONSE 2 j i
The regulatory requirements allow some considerable latitude to the licensee to select a mode of decommissioning at the end of the operating life of the plant. In general, the most expensive l mode of decommissioning would be prompt total dismantlement; the [
1 east expensive mode of decommissioning would be mothballing the l facility. Since the ultimate mode of decommissioning is selected '
at the end of the plant operating life based upon values and ;
considerations at that time and subject to regulatory approval, l it is only necessary to demonstrate that the potential allowable [
modes are feasible to the fact that the plant can be decommissioned. It has been demonstrated that the most severe i and expensive mode, total dismantlement, is technically and i economically feasible. Further speculative analyses serve no !
I additional value.
Results of prior decommissioning activities show that cace levels j of neutron activation and contamination of systems are reached which require remote removal techniques, the specific isotopic content and distributions have a negligible impact on the costs of decommissioning. j
. l l
SET XVIII AD ,
. . i l
INTERROGATORY 3 What are the environmental impacts and unavoidable adverse ;
environmental erfects of decommissioning CRBR? Provide all' documentation bearing on thic question.
RESPONSE 3 The response to this question is contained in Section 5.9 of the CRBRP Environmental Report, l
P e
SET XVIII , AD L-- m n -
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FIGURE 13.3A-2 ELAPSED EXPOSURE TIME TO REACH SPECIFIC LUNG DOSE VERSUS DOWNWIND DISTANCE (BASED ON SITE SUITABILITY SOURCE TERM)
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l l
FIGURE 13.3A-3 ELAPSED EXPOSURE TIME TO REACH SPECIFIC THYROID DOSE VERSUS DOWNWIND DISTANCE (BASED ON SITE SUITABILITY SOURCE TERM)
(
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Amend. 65 13.3A-3 Feb. 1982 l
FIGURE 13.3A-4 ELAPSED EXPOSURE TIME TO REACH SPECIFIC WHOLE BODY l
DOSE VERSUS DOWNWIND DISTANCE r (BASED ON SITE SUITABILITY SOURCE TERM)
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- 13. 3.^.- 9
?M .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of .)
Department of Energy .)
DOCKET No. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY .)
AFFIDAVIT OF Raymond Cooperstein, being duly sworn, deposes and says se follows:
- 1. That he is employed as Environmental Protection Specialist, Office of Nuclear Safety, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered V.2 and V.3 in the eighteenth net.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
K.Qw Q (de ,15%:
N Signa e SUBSCRIBED and SWORN to before me this S '/ . day of Os> # r /. , 1982.
n Th% 4'). . b dvN: Aj.l Notarf Public My Commission expires e 19_.
pan'JCA c., otgggggg WI'I, 8 'J"L'C $TATU Cr MARYLAND
% uom ,~. :n Espires My g, g 7og L +
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
UNITED STATES DEPARTMENT OF ENERGY DOCKET N0. 50-537
)
PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF JAMES F. MURDOCK James F. Murdock, being duly sworn, deposes and says as follows:
- 1. That he is employed by U. S. Department of Energy as Senior Reactor Engineer, CRBRP/P0, P. O. Box U, Oak Ridge, TN 37830.
- 2. That he is duly authorized to answer the Interrogatories numbered VI-1.a-d, -2, -3 dealing with Contention 8 in NRDC's Eighteenth Set of Interrogatories dated April 15, 1982.
- 3. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
W .
gnature
'[
SUBSCRIIsED and SWORN to before me this 3 0 day of 1982 Notary P dlic My Commission Expires Apr!! 21 iMi
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
UNITED STATES DEPARTMENT OF ENERGY ) DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION )
TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF DENNIS M. SWITICK Dennis M. Switick, being duly sworn, deposes and says as follows:
- 1. That he is employed by the General Electric Company as Manager, Safety Analysis, Advanced Reactor Systems Department, 310 De Guigne Drive, Sunnyvale, California 94086.
- 2. That he is duly authorized to answer the interrogatories numbered 11-1, and 11-3 in NRDC's Eighteenth Set of Interrogatories.
- 3. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
w:(Signatufe) W.
Subscribed and sworn to before me this /f* day of eft , 1982.
i 1
/
Y otary d=YPublic I l
My Commission expires 9[tg[/4/ ~ .
1
1 I
UNITED STATES OF AMERICA
- I NUCLEAR REGULATORY COMMISSION In the Matter of ) .
DEPARTMENT OF ENERGY )
DOCKET NO. 50-5,37 PROJECT MANAGEMENT CORPORATION
)
TENNESSEE VALLEY AUTHORITY ) .
APPIDAVIT OF PAUL w. DICKSON JR. __
being duly sworn, deposes and says as follows:
- 1. That' he is employed by Westinghouse Electric Corporation -
og Technical Director, Clinch River Broeder Reactor Projectf Westinghouse Advanced Reactors Division, Post Of fice box W, Oak Ridge, Tenn. 37830 ,
, - _ - ~ ~ ~
^^ ~ '
__ .P
- 2. That he is duly authorized to answer the Interrogatories I (1-9'12-15,17) 11 (2,4-5[__
ndmbered -
in NRDC's Eigh teen th -_- set of Interrogatorles.
,3. That the above-mentioned and attached answers 'are true and correct to'the.best of his knowledge and belief.
~
__ f J W AR , f~"" ~ ~
SIGNATURE
. 2%.
SUBSCRIr,UD and SWORM t s tcf ore pc- t hin .$8,..., day of '
ALM' '
, 1982.
, z
. /> - A./I&[ ~
Nota Publ i c.' .
My commission expiros __ - , 19 - .-
My Commission Expires April 28,1984 0019-9E9,Sid 39018 >lWO dM883 1ND 21:03 083/Wb0
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
UNITED STATES DEPARTMENT OF ENERGY)
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION )
TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF George Macrae being duly sworn, deposes and says as follows:
- 1. That he is employed by Westinghouse Electric Corporation as Manager of CRBRP Plant Protection Systems.
Westinghouse Advanced Reactors Division, P. O. Box 158, Madison, Pennsylvania 15663.
- 2. That he is duly authorized to answer the Interrogatories numbered 1-13, 1-14 & 1-15 in NRDC's 18th set of Interrogatories, and in NRDC's set of Interrogatories.
- 3. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
Signature Subscribed and sworn to before me this 28th day of Aoril ,1982.
A<7A hotaryPublig D
MART G H4YDEN. NOTARY PUBUC
Pty Consission expires _sEwicyjEY TWP,WESTMORELAND. COUNTY'
-i w-av, vrmo e tu. 43,19M Me.nber. Pennsyfvama Assocation of.Notanes
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
UNITED STATES DEPARTMENT OF ENERGY ) DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION )
TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF LEE E. STRAWBRIDGE Lee E. Strawbridge, being duly sworn, deposes and says as follows:
- 1. That he is employed by Westinghouse Advanced Reactors Division as Manager, Nuclear Safety and Licensing, P. O. Box 158, Madison, Pennsylvania 15663.
- 2. That he is duly authorized to answer the Interrogatory numbered 11-3 in NRDC's Eighteenth Set of Interrogatories.
- 3. That the above-mentioned and attached answer is true and correct to the best of his knowledge and belief.
Ek
- ' (Signature)
~-
Subscribed and sworn to before me this ff* day of jfz , 1982.
4/L .
My Commission expires 9[#[M .
l l
l l
I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
U. S. DEPARTMENT OF ENERGY ) DOCKET N0. 50-537 PROJECT MANAGEMENT CORPORATION,
)
and TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF EDWARD F. PENICO Edward F. Penico, being duly sworn, deposes and says as follows:
- 1. That he is employed as Security Consultant for the CRBRP Project, and that he is duly authorized to answer Interrogatories III l-5 (Contention 4 and 6(b)(4)), Eighteenth Set, dated April 15, 1982.
- 2. That the above mentioned and attached answers are true and correct to the best of his knowledge and belief.
J W==
Signature '
"Qs )
SUBSCRIBED and SWORN to before me this 80 days of M/2.s[ 1982 I
f.
Notary P@lic 1 Commission Expires April 28, tm I
UNITED STATES OF AMERICA NUCl. EAR REGULATORY COMMISSION I
In the matter of .)
Department of Energy ,) :
PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE YALLEY AUTHORITY ,)
. i '
AFFIDAVIT OF Dr. F. C. Gilbert, being duly sworn, deposes and says i as follows:
l
- 1. That he is employed as Deputy Assistant Secretary for Nuclear t
Materials, Defense Programs, U.S. Department of Energy, and '
that he is duly authorized to answer interrogatories numbers V.4 ~ '
and V.5 in the eighteenth set.
2.
That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
i A (
.Y Signature ; j i
SUBSCRIBED and $ WORN to before me this ._I day of _/f, y ,1982.
.s (
c l
GNE '. aJ h. &OA./* r r]3 a.D Notary Putrite r-
,V
% Cannission expires 19 .
PATR' CIA U. CILiv.DdlG t!CtM.Y c1st at" '-? 7 CF AMPYLAND My C:c asse; Exps:s Ju'y *. Mr.2
.:a j'
i mm r l UNITED STATES OF AMERICA j NUCLEAR REGULATORY C0tEISSION t
In the matter of .) j Department of Energy ,)
DOCKETNO.55-537 PROJECT MANAGEMENT CORPORATION and.) l TENNESSEE VALLEY AUTHORITY .) i m.... .. arrinaV4LDE uwdahm A lennenec(er Ae440 dul.v.. sworn demoses and says. ,
M Adlenut: l
- 1. That he is employed as Manager, Licensing and Environmental Coordination, Office of Nuclear Energy, U.S. Department of Energy, and that he is duly authorized to answer interroga- ,
tories numbers V.1, VI.1, VI.10 and VI.12-22 in the eighteenth set.
- 2. That the above-mentioned and attached answers are true and 6
correct to the best' of his knowledge and belief.
e -_ _ .A Signgure SUBSCRIBED and SWORN to before me this .7 / day of ///v / // , 1982.
(
/) {!
-) 2.6 i n 'a. 4 . 6 d; ,,.i , a l Notary Public y l My Commission expires , , 19_.
l l w w. a c-..ax. .
\
?DIMY Fl.f'Ur f TV.i er ygyW;p j
,. My C n *:*0:n Empires I..!f1,1932
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ,)
Department of Energy ,)
DOCKET N0. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,)
AFFIDAVIT OF Michael Lawrence, being duly sworn, deposes and says as follows:
- 1. That he is employed as Acting Director, Office of Nuclear Fuel Cycle, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered V.6, V.9 in the eighteenth set. ,
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
WM Signatufe m=~ n _ ,
SUBSCRIBED and SWORN to before me this 47($ day of c, x , L , 1982.
S$ Notary Pulflic.b /ErbJJ My Commission expires , 19 .
PAftl CIA O. CILIMBERG NOTARY PUBLIC STATE OF MARYLAND A4y Commission Empires July 1,1902 f
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of .)
Department of Energy ,)
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY ,) l l
I AFFIDAVIT OF Austin Wiles, being duly sworn, deposes and says as follows:
- 1. That he is employed as a Traffic Manager, Office of Defense Waste and Byproducts. U.S. Department of Energy, and that he is duly authorized to answer interrogatory number V.7 in the eighteenth set.
- 2. That the above-mentioned and attached answer is true and correct to the best of his knowledge and belief.
L a signature WA>
SUBSCRIBED and SWORN to before me this R f_ day of [pft,L ,1982.
i cLS.& .O l. 0.hbo Lje Notary P6blic l % Commission expires , 19,,_.
PArgr!A o, enes>P g NOT' ~ v t d'cK " . * s~ s" '*/ tY: AND My Cem. *.....:. I.<; M p 1,17:'2
i UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY C0ttilSS' ION ,
In the Matter of )
) ~
U. S. DEPARTMENT OF ENERGY, DOCKET N0. 50-537
~
PROJECT MANAGEMENT CORPORATION, ) '
)
and TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF RAYMOND L. COPELAND .
Raymond L. Copeland, being duly sworn, deposes and says as,follows: .
1 That he is employed as Acting Assistant Director, Public Safety .
Division CRBRP Project, and that he is duly authorized to answer Inter-rogatories I-10,1-18, and IV-1 in the Eighteenth ' set of Interrogatories.
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- 2. That the above-mentioned and attached answers are true and
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correct to the best t,f his knowledge and belief. , _ _
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SUBSCRIBED and SWORN to before me !
this AM- day of May, .1982. .
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,. N6tary Public ;
My ofddn'cr E,:;;!m Ap!il 2810M l l l
UNITED SDGES OF AMERICA NUCLEAR REGULA'IORY COMMISSION In the matter of ) UNI'IED STATES DEPAR'INENT OF DEGY) DOGET 10. 50-537 PROJECT MANMIEMENT 00RIORATION )
'IENNESSEE VALLEY AUIHORITY )
AFFIDAVIT OF PAUL W. DIN mNj [P. Paul W. Dickson, being duly sworn, deposes and says as follows:
- 1. 'Itat he is employed by Westinghouse Electric Corporation as Technical Director, Clinch River Breeder Reactor Project, Westinghouse l Advanced Reactors Division, Post Office Box W, Oak Ridge, Tennessee 37830.
- 2. 'Itat he is duly authorized to answer Interrogatory 16 for Contentions 1, 2, and 3 in NRDC's 18th set of Interrogatories.
- 3. 'Itat the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
Y 'r(Signature) J1vWl Subscribed and sworn to before me this 4th day of May,1982. W ' Notary Public My Comission expires
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k' PROJECT W.MAGEMENT @RPORATION and.) ft TEllNESSEE VALt.EY AUTHORITY .) , , _ , f h willies A. Biginbothas, being duly 8vorn, deposes and says as AFFIDAVID OF g j follows:
- 1. That he is employed as Senior Scientist, Department of Wyclear Energy, Y 0
Brookhaven Natiousl Laboratory, and that he is duly authorized to aniver l Y interrogatories number 111.1.a and b in the eighteanth set. [ $
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- 2. That the abovewntioned and attached enevers are true and correct to the
( best of his knowledge and belief. l 0
@ ; LSignaturs/li % I-a L ,
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? day of & , 1982. 3 SUBSCf.IBED and SWORN to before at this g (
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WUCLEAR REGULATORY COMMISSION j 1 l In the matter of .) 1 Department of Energy ,)
- DOCKET No. 50-537 f PA0dECT MANAGEMENT CORPORATION and,) !)3 i
TENNESSEE VALLEY AUTHORITY .) ]' 1, 1 AFFIDAVIT OF Glenn Hamond, being duly sworn, deposes and says as follows: d
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- 1. That he is employed as Chief, Technical Development and !f (
Implementation Branch. Office of Safeguards and Security, 0'_j 1l . U.S. Department of Energy, and that he is duly authorized j to answer interrogatory nusabers III.4 and III.3 in the ;[> ' eighteenth set. !'
- 2. That the above-mentioreed and attached answers are true and ;.
correct to the best of his knowledge and belief. Ml , il t hl
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'AVk h-Signature _'__
il' l SUBSCRIBED and SWORN to before me this M day of _//74 ./ , 1982. j
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Notary Public ; l l My Comunission expires _ . 19_. il PATRfCIA G. CILIM6 ERG ~' MARY PUBLIC 51 ATF OF MArvtAND My Commission Emires Ju'y 1, IP!2 l
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UNITED STATES OF AMERICA , NUCLEAR REGULATORY COMMISSION 3 , 4 d; In the matter of .) ' Department of Energy .) ; DOCKET NO. $0-537 PROJECT MANAGEMENT CORPORATION and,) g TENNESSEE VALLEY AUTHORITY .) AFFIDAVIT OF John Stewart, being duly sworn, deposes and says as follows: !
- 1. That he is employed as Program Analyst, Office of Safeguards and
- Security, U.S. Department of Energy, and that he is duly authorized k to answer interrogatory numbers III.1.C. III I.D and 111.5 in the "
eighteenth set.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief. ;;
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Signature j SUBSCRIBED and SWORN to before me this /,/ day of /n n w/ , 1982. 1 O {,
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Wotary Pdblic Urr-l-Uf , ; I 7
% Commission expires , 19 . ,:
PATR1CLA O. CElmeno pgl)TARY PUBUC $ TATE Of MARYLAND myc ; ;engapiresMy 1.190t 4 h
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l I
) l In the Matter of ) l
)
UNITED STATES DEPARTMENT OF ENERGY )
)
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
)
TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
)
CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class umil to the following:
*** Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission 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)
-2_
- Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission .
Washington, D. C. 20545
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission
, Washington, D. C. 20545
- Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Commission ,
Washington, D. C. 20545 (3 copies) ; William M. Leech, Jr., Attorney General l William B. Hubbard, Chief ( Deputy Attorney General ; Lee Breckenridge, Assistant : Attorney General l State of Tennessee ' Office of the Attorney General l 450 James Robertson Parkway , Nashville, Tennessee 37219 i Oak Ridge Public Library ' Civic Center Dak Ridge, Tennessee 37820 i Herbert S. Sanger, Jr., Esquire ! Lewis E. Wallace, Esquire l W. Walter LaRoche, Esquire l James F. Burger, Esquire
- Edward J. Vigluicci, Esquire !
Office of the General Counsel ' Tennessee Valley Authority 400 Commerce Avenue i Knoxville, Tennessee 37902 (2 copies)
**Dr. Thomas Cochran I Barbara A. Finamore, Esquire l Natural Resources Defense Council '
1725 Eye Street, N. W., Suite 600 l Washington, D. C. 20006 (2 copies) l 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 l
l I 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 Silverstrum, 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 7'
4MicrgM Edgar f Attorney for Project Management Corporation DATED: May 4, 1982 l
*/
Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
**/ Denotes hand delivery to indicated address. ***/ Denotes hand delivery to 4350 East-West Highway, Bethesda, Md.
_ _ - _ _ _ _ _ _ _ _ _ - _ . ,}}