ML20052H845
| ML20052H845 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 05/20/1982 |
| From: | Copeland R, Ogg W, Piper H JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205240062 | |
| Download: ML20052H845 (37) | |
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May 20, 1982 UNITED STATES OF AMERICA ~r 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 MANAGEMENT CORPORATION ) Docket No. 50-537
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TENNESEE VALLEY AUTHORITY )
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(Clinch River Breeder Reactor Plant) )
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APPLICANTS' SECOND RESPONSE TO NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND SIERRA CLUB EIGHTEENTH SET OF INTERROGATORIES Pursuant to 10 C.P.R. Section 2.740b. and in 'ccordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy and Project Management
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Corporation, for themselves and on behalf of the Tennessee Valley Authority (the Applicants), hereby file their Second Response to the Natural Resources Defense Council, Inc. and the Sierra Club Interrogatories dated April 15, 1982 1 Eighteenth Set of 1 Applicants previously responded to the Eighteenth Set of i Interrogatories on May 4, 1982. Applicants hereby respond to the following outstanding interrogatories in the Eighteenth Set: I, 11; l VII, 1, 3, 4-5 (2 withdrawn); V 8a.; and VIII. Applicants have proceeded to provide these responses in an effort to expedite these proceedings. In providing these responses, Applicants do not l
concede that the information is admissible in or necessary to a decision in the LWA proceedings. Intervenors should contact Warren gQs Bergholz (202/252-6975) to make arrangements for inspection and copying of documents. / f 8205240062 820S20 PDR ADOCK 05000537 G PDR
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Answers to General Ouestions (a) - (f) are as follows:
1 Unless not applicable, the answers to general questions (a)
(f) are as follevs:
(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 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 documets 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 heading " DOCUMENTS"; none.
'( d ) Identify by name, title and affiliation the primary Applicant employee (s) or consultant (s) who provided the answer to the question.
ANSWER: See the attached affidavit (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 i
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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 question or for a group of related questions.
This answer need not be provided until Applicants have in fact identified the expertss) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.
ANSWER: Applicants have not yet identified the expert (s) in question.
I. CONTENTIONS 1, 2. AND 3 INTERROGATORY 11 The November 9, 1978 letter from William P. Gammill of the NRC Staff to Lochlin W. Caffey summarizes the Staff's position regerd-ing the major unresolved CRBR safety issues at the time the CRBR licensing proceeding was suspended. Briefly describe Applicants' position in regard to Items I A, B, C, E, J; II A, B, C, D; III A, B; IV C, H, I; VA, B; VI A; VII A, B, C, D; VIII A, B, C; IX A, B, C, D, F, G, H.
RESPONSE 11 I. GENERAL A. Control Room Desion Conformance with CRBRP Criterion 17
- 1. The radiological analysis assuming the Staff's speci-l fled site suitability source term has been completed l and the results included in PSAR Section 6.3 in Amendment 49. Radiological analyses for the hypothetical core melt are included in a topical report CRBRP-3, Vol. 2, " Hypothetical Core Disruptive Accident Considerations in CRBRP; Assessment of Thermal Margins Beyond the Design Base" incorporated I
by reference in PSAR Section 1.6 in Amendment 54.
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- 2. PSAR Section 3.1.3.1 and Section 7.4.3 provided, (Amendment No. 32 and 57) functional requirements for remote control (Remote Shutdown System) which are believed to satisfy the remote reactor control requirements of NRC and CRBRP Design Criteria 17.
l These Sections will be expanded further in the i response to NRC Question CS 421.17.
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5-I. B. Laroe Sodium Releases in Steam Generator Buildino (SGB)
- 1. PSAR Section 15.6 was revised in Amendment 64 to address this.
- 2. The sodium fire protection system relies on an Engineered Safety Feature catch pan with fire suppression deck augmented by support equipment.
Information concerning the sodium fire protection systems is described in PSAR Sections 6.5 and 9.13.2, provided in Amendment 64 and 54, respectively.
I. C. Imolementation of Desion Criteria These have been adopted by the Project and were provided in PSAR Sections 3.1 and 3.2 in Amendment Nos. 32 and 26, respectively.
I. E. Safeguards The new requirements promulgated in 10 CFR 73.55, February 1977 and subsequent new requirements on safeguards, have been incorporated in Sections 9.11 and 13.7 of the PSAR by Amendment Nos. 47, 61, and 68.
I. J. Meteoroloov Additional wind data has been taken at the 33 foot level for the required period of one year. This additional information was provided in PSAR Section 2.3 in Amendment 65.
- 6-II. CONTAINMENT SYSTEM DESIGN A. Laroe Sodium Releases and Design Basis Accidents The Project has specified a DBA for the containment (PSAR Section 6.2) which it believes to be conser-vative in that it includes assumptions that the largest hypothetically available sodium volume spills into an air-filled cell and that 100% of the oxygen in containment is consumed by combustion with the spilled sodium. The Project has included features to ensure protection for this event and spills of potentially radioactive sodium in other cells of the Reactor Containment and Service Buildings. These features include an Engineered Safety Feature Cell Liner System, which is discussed in PSAR Section 6.4. In addition, the Project has committed to prudently mitigate the results of hypothetical accidents beyond the design basis. Required equipment for this event will be qualified to the hostile environments as is discussed in a report CRBRP-3, Volume 2, " Hypothetical Core Disruptive Accident Consideration in CRBRP; Assessment of Thermal Margins Beyond the Design Base."
II. _. Accommodation of Enercetics The Project believes that further technical interactions are neceesary with the NRC Staff to resolve the energetics issues. The Project has submitted on April 20, 1982, the updated report CRBRP-3, Vol. 1, " Hypothetical Core Disruptive Accident Considerations in CRBRP; Energetics and Structural Margin Beyond the Design Base," which provides the current information related to the analytical and experimental bases for specification of
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energetics, the analyses supporting the design capability to withstand these, and the results of the supporting SRI scale model tests.
II. C. Accommodation of Melt-Down The issues identified by NRC are addressed in a report CRBRP-3 Volume 2, " Hypothetical Core Considerations in CRBRP; Assessment of Thermal Margins Beyond the Design Base."
II. D. Accommodation of Site Suitability Source Term The Project believes that further NRC Staf f review will support its initial conclusion that the Project position and documentation (revised PSAR Chapter 15A submitted by Amendment No. 40 and 57) are acceptable.
The Project provided the description of the filtration of the 'tSB in PSAR Section 6.2.6 in Amendment No. 36.
III. THERMAL-HYDRAULIC DESIGN A. Natural Circulation and Low Sodium Flows The Project, in response to NRC Question 001.580 in Amendment No. 32, committed to analyses and testing which will confirm the natural circulation capa-bilities of CRBRP. Additionally, the Project has supplied pre-test predictions of natural circulation tests at FFTF in February 1981, using CRBRP methodologies and computer codes. A report will be prepared consolidating these pre-test predictions and post-test analyses for submittal to NRC by October, 1982.
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III. B. Hot Channel Factors WARD-D-0050 was revised and submitted for NRC review along with revised PSAR Section 4.4 in Amendment 51.
IV. MECHANICAL / STRUCTURAL DESIGN C. Control Rod Systems The PSAR, amended in Amendment 59, reflects the current design of the SCRDMs.
IV. H. Active Pumo and Valva Operability The Project has provided details of the Active Pump and Valve Operability Program in Sections 3.9 and report WARD-D-0174, incorporated by reference into Section 1.6 of the PSAR in Amendment No. 44.
IV. I. Structural Desion The Project provided the requested information in PSAR Section 3A.8 in Amendment No. 45.
V. PIPING INTEGRITY (AEB)
The Project has addressed the questions raised related to the size of leak in the response to NRC Question 001.581; leak detection and the hot leg piping integrity in WARD-D-0185, " Integrity of Primary and Intermediate Heat Transport System Piping in Containment"; and material surveillance in PSAR Amendment Nos. 32, 40, and 42. As stated in PSAR Section 15.6.1.4 the Project is using the leakage rate f or piping with low internal pressure specified by the NRC (BTP MEB 3-1) for cell and cell liner
design. The Project believes this information will provide the basis for resolution of these items.
A revised Appendix G to the PSAR, "CRBRP Plan for In-service Inspection was submitted to the NRC in Amendment 65. The material presented in the revised Appendix G represents the Project implementation of a practical inservice inspection program.
VI. ELECTRICAL
- A. Reactor Shutdown System (RSS)
The original information addressing the integrated design capability to satisfy the redundancy, diversity, and reliability requirements and the design criteria have been augmented in the following PSAR Sections and Tables:
Sections 4.2, 7.1, 7.2, 7.5, 7.7, 15.1, 15.2 Tables 15.2-1, 15.3-1, 15.1.3-3 i
Q/R's 222.13, 222.67, 001.313, CS421.01, CS421.02, CS421.03, CS421.09, CS421.10, CS421.19 VII. FUEL DESIGN (A, B, C, D)
! PSAR Section 15.1.2, " Requirements and Criteria for Assessment of Fuel and Blanket Rod Transient Performance,"
as revised in Amendment 61, provides the fuel design limits which assure cladding integrity is maintained through normal operation and all off normal events.
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j The Project has supplied topical reports listed below which, together with the information presented in PSAR Section 4.2.1.3 and Table 4.3-5A, provide the information defining the current status and planning for* these areas.
The submittal status of the eleven listed items is summarized below.
- 1. Fuel densification PSAR Amendment 40, WARD-D-0168
- 2. Fuel Rod Bowing PSAR Amendment 30, WARD-D-0150
- 3. Fuel Rod Vibration PSAR Amendment 35, WARD-D-0166
- 4. Fuel Rod Wire Wrap PSAR Ahendment 43, WARD-D-0149 Interaction
- 5. Fuel Assembly Structural PSAR Amendment 57, CRBRP-ARD-Evaluation 0204
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- 7. Fuel Rod Seismic Analysis PSAR Amendment 37, WARD-D-0158
- 8. Internal / External PSAR Amendment 41, WARD-D-0147 Cladding Degradation
- 9. Fuel Restructuring Submittal to be made after' completion of LIFE code verification
- 10. Fuel Rod Failure Criteria PSAR Amendment 27, no separate report
- 11. Exposure Dependent PSAR Amendment 27, WARD-D-0146 Deformation
The Project has designed provisions to detect failed fuel including fissf on gas monitors, sodium sampling and i !
analysis, and delayed neutron detectors in addition to the plant instrumentation. Based on current experimental and analytical data, fuel failures can be detected and appropriately characterized using these design provisions.
Additionally, accident analyses are discussed in detail in ,
PSAR Section 15.4 and the Project's response to fuel failure propagation concerns in a September 20, 1976, transmittal to the NRC.
The response to these detector signals and operating limitations will be established during the NRC Staff review of the final technical specifications.
l VIII. SYSTEMS A. Fire Protection System i
Since the initial release of Apper. dix A, the NRC has issued Regulatory Guide 1.120, Rev. 1 (issued in l November 1977), BTP ASB 9.5-1, Rev. 1 (issued in March 1978) and Appendix R to 10 CFR 50. The Project design was evaluated using these documents and is being revised to conform with the intent of the NRC guide-lines. The NRC issues will be resolved as individu-ally addressed below:
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- 1. A complete response to NRC Question 20.47 concerning the latest NRC fire protection requirements was provided in Amendment No. 48 in February, 1979,
- 2. The Project his made a preliminary determination of fire haztrds which was submitted in Amendment No. 48. the Project is preparing a detailed fire hazards analysis which will be in final form by July 30, 1982 and included in the FSAR.
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- 3. Information clarifying intermediate coolant system !
flammability and combustibility is currently included in PSAR Section 9.7 supplied in Amendment No. 44.
- 4. The listing of fire barriers in Table 9.13-1 has been updated and was supplied with Amendment No.
- 48. The ratings will be supplied as the design develops and the fire hazards analyses are conducted in each individual area.
- 5. The nitrogen flooding and carbon dioxide systems have been deleted from the design. The P&ID for the Halon System is included in Section 9.13 by Amendment 54.
- 6. Information concerning the assessment of sodium carbonate fire extinguisher suitability in liquid metal areas is included in Section 9.13.2 by Amendment 54.
VIII. B. Shutdown Heat Removal System The Project has requested that a meeting be scheduled to discuss the NRC issues in detail and determine the basis for resolution.
VIII. C. Reliability The Project recommends that this potential use of reliability as well as other questions raised be discussed in the meeting requested in Item VIII.B.
above to discuss the NRC decay heat removal issues.
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IX. ACCIDENT ANALYSIS (RADIOLOGICAL)
A. Continuous Containment Purae The Project has provided the definition of design basis events (PSAR Section 6.2.4.1) and the supporting analyses to the NRC in Amendment Nos. 30, 36, 45, and 64 to the PSAR.
IX. B. Open Hatch Refuelino The Project has included a confinement capability in i the RSB. The confinement capability (discussed in PSAR Sections 9.6.3 and 6.2.6 in Amendment No. 36 and
- 64) further reduces potential offsite consequences of postulated accidents during refueling.
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IX. C. Steam Generator Tube Failures l
l The design does not depend solely on the integrity of
! the IHX to prevent release of primary sodium to the environment. The plant design precludes the direct driving of primary sodium to the steam generator and atmosphere through this postulated scenario of IHX tube leak coupled with steam generator tube rupture.
PSAR Section 15.7.3.5 discusses an IHX tube leak event. PSAR Section 15.7.1.3.5 outlines the CRBRP intermediate system design to preclude the event of primary sodium leakage to the steam generator system.
IX. D. Sodium Fires J
Plant Engineered Safety Features to mitigate the effects of sodium fires in the SGB are discussed in PSAR Section 6.2.7. A thermal and aerosol consequence assessment of such a sodium fire in the SGB is discussed in PSAR Section 15.6.1.5.3.
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IX. F. cold Trao Fires i Additional information in the form of analydis was requested in NRC Question 310.49. The Project has provided such analysis in the response to NRC Question 310.49 in Amendment No. 45.
IX. G. Instrumentation to Follow the Course of an Accident
- 1. The Project has recently completed a detailed review and evaluation of Regulatory Guide 1.97, Rev. 2. This will be further documented in the PSAR in the near future.
- 2. The Project intends to provide instrumentation such that tra plant operators will have sufficient information to make the appropriate decisions with respect to initiation of TMBDB features. The instrumentation is discussed in CRBRP-3, Vol. 2,
" Hypothetical Core Disruptive Accident Considerations in CRBRP: Assessment of Thermal Margins Beyond the Design Base."
IX. H. Risk Associated with Nearby Industrial Activities The proposed Exxon facility was removed from the NRC docket in 1980 and is no longer considered as having a potential impact on the CRBRP. An updated discussion of nearby Industrial Facilities will be provided in Section 2.2 of the PSAR.
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Suoclemental Answer to Interroaatory No. III, lb) and 2 The following additional classified document was located in the process of preparing unclassified summaries of the two documents previously listed:
Shortest Sabotage Paths for the CRBRP, SAND 77-1710, Daniel and Darby (CNSI) .
An unclassified summary of this document will be prepared and made available for inspection and copying.
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V. Contention 6 Ouestion 8 If plutonium for the CRBR may be obtained from the United Kingdom,
- a. What regulations would govern the transportation of such materials?
Resoonse 8 In the hypothesized situation, International Atomic Energy Agency (IAEA) regulations would apply. The Department of Transportation is
, the U.S. national competent authority with respect to the administration of these IAEA regulations for the safe transportation of radioactive materials. (49 C.F.R. Part 173).
Documents None.
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VII. GENERAL OUESTIONS INTERROGATORY l Provide copier of "y and all documents in the possession of Applicants not preyttisly provided to Interverors, relating to communications between Staff and Applicants since April 23, 1977 regarding the licensing of the CRBRP.
RESPONSE 1 See Applicants' Updated Response to Natural R'! sources Defense Council, Inc. and the Sierra Club First Set of Interrogatories to Applicants dated April 30, 1982. The follcwing supplementary list of documents cover items since April 7, 1982.
Set 18 VII No. 1 Supplementary List From/To Date Subject Longenecker to Check 4/07/82 WARD D 0165 Rev. 6 CRBRP Request
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for Environmental Qualification of Class lE Equipment Longenecker to Check 4/29/82 Amendment No. XII to ER Longenecker to Check 5/03/82 CRBRP Fuel Cycle Longenecker to Check 4/20/82 Revised CRBRP-3, Vol. 3, HCDA Considerations; Energetics and SMBDB
Longenecker to Denton 4/06/82 Affidavit on Dist. of Amendment No. 67 to CRBRP Safety Analysis
- Report Longenecker to Check 4/14/82 Response to Request for Additional Information-Clinch River Security System Longenecker to Check 4/21/82 Response to Request for Information-Chemical Engineering Longenecker to Check 4/19/82 Response to Request for Information-Inservice Inspection Longenecker to Check 4/26/82 Response to Request for Additional Information-Inservice Inspection Longenecker to Check 4/29/82 Response to Request for Additi,>nal Information-Effluent Treatment Longenecker to Check 5/07/82 Response to Request for -
Additional Information Effluent l Treatment Longenecker to Check 5/07/82 Response to Request for Additional Information-Equipment Qualification l
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INTERROGATORY 3 Provide copies of any and all documents in the possession of Applicants not previously provided to Intervenors, relating to communications between Applicants and ACRS since April 23, 1977 regarding the licensing of the CRBRP.
RESPONSE 3 Letter from Donald G. Robinson to Public Safety Division Files, Review of Transcript of December 7, 1979, ACRS Committee Meeting, dated January 9, 1980 Letter from Longenecker to Boehnert, " Proposed Agenda for May 4 and 5 Meeting on Initiation Phase of HDCAs," dated April 19, 1982 Letter trom Longenecker to Boehnert, " Proposed CRBRP Agendas for the May 24 and 25 Meeting on Containment Design and Evaluation, and the June 1, 1982 Meeting on Seismic Design," dated i
May 18, 1982.
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INTERROGATORY 4 Provide all documents, memoranda or communications in any form between or among Project Management Corporation, TVA and DOE related to the issues raised by NRDC's contentions.
RESPONSE 4 Refer to Applicants' Response of Set 18, VII, No. 5.
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INTERROGATORY 5 Project Management Corporation, TVA and DOE are each asked to provide all internal memoranda, minutes of meeting (including but not limited to Board meetings) or' documents of any kind related to the issues raised by NRDC's contentions.
RESPONSE 5 Document Search List Report The Clinch River Breeder Reactor Plant Project: Chief Executive Briefing, Proceeding's of the Breeder Reactor Corporation May 1977 Information Session, CRBRP-PMC 77-04 Memo PS:81:005, K. Yates to R. Copeland, " Summary of Hearing Documents," dated 1/5/81 Letter PS:82:055, R. L. Copeland to Multiple Addressees, l " Summary of Exemption and Environmental Hearing Documents,"
dated 2/18/82 Letter PS:82:189, R. L. Copeland to Multiple Addressees,
" Summary of Exemption and Environmental Hearing Documents,"
dated 5/11/82 Letter, R. Woolley to T. Dobry et al, "Intervenor Contentions in CRBRP Licensing Proceeding," dated May 13, 1982
" Update Summary of Intervenor Contentions in CRBRP Licensing Proceeding," dated April 16, 1982 Memo, H. Piper to R. Woolley, " Listing of NRC Correspondence (NRDC Restated Contention)," dated April 9, 1982 l
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Notes, " Basis for Revisions to Existing NRDC Contentions and for New Contentions," dated March 1, 1982 Paper, "
New Information Relevant to Intervenors' Contentions" Transcript, " Appendix to Transcript of CRBRP Prehearing Conference Admitted Contentions of Intervenors NRDC, Inc. and the Sierra Club as of April 7, 1982, dated April 9, 1982 O
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VIII. The Followina Interrocatories Relate to the contentionsts)
Indicated in Parenthesis Followino Each Document. Event, or Procram:
With regard to each of the following documents, events, or programs, indicate, by answering the following questions, the extent to which applicants have considered or intend to consider such document, event, or program in determining whether one or more Amendments to Applicants' Environmental Report (ER) have been or must be prepared after April 25, 1977:
- a. Have Applicants considered the impact of this document, event, or program on their environmental analysis?
- b. If the answer to a. is yes, briefly describe the extent to which Applicants have considered this document.
INTERROGATORY 8 NRC proposed rule requiring improvements in reactor design to reduce the risks from anticipated transients without scram
("ATWS") events (46 Fed. Rec. 57521, November 24, 1981)
(Contention 1):
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RESPONSE 8
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- a. No,
- b. Not applicable.
INTERROGATORY 9
Risk Assessment Review Group report to the U.S. Nuclear Regulatory Commission (NUREG/CR-0400) (Contention 1);
RESPONSE 9
- a. No.
- b. Not applicable.
INTERROGATORY 10 Nuclear Regulatory Commission Statement of Risk Assessment in Light of the Risk Assessment Review Group Report, January 18, 1979 (Contention 1);
REPONSE 10
- a. No.
- b. Not applicable.
INTERROGATORY 11 U.S. Nuclear Regulatory Commission, ERC Ac' tion Plan Dp.elooed AR A Result 21 thg TMI-2 Accidents (NUREG-0660) (August 1980)
(Contentions 1 and 3);
RESPONSE 11
- a. No.
- b. Not applicable.
INTERROGATORY 16 Significant changes in reactor vessel and core design that must be reflected in Applicants' accident modeling (See, e.g., PSAR Sections 4.1 and 4.2) (Contention 2).
RESPONSE 16 Reactor Vessel -
- a. No.
- b. Not applicable.
Core Design -
- a. Yes.
- b. As a result of the change to a heter-ogeneous core design, the appropriate changes were made to the various physical quantities and radiological source terms used as inputs to l Applicants' accident modeling, e.g., in l
Section 7.1, " Plant Accidents."
INTERROGATORY 17 New results on ongoing safety testing (see, e.g., pp. 118-135 of DOE Draft EIS Supplement (DOE /EIS-0085-D) and footnotes 4, 7, 8< 9, 10l, 13, 14, 15, 16 on pp. 141-144); sag also General Electric, An Assessment af HCDA Enercetics in tha CRBRP Heterogeneous Reactor Core (CRBRP-GEFR-00523) (December 1981)
(Contention 2):
RESPONSE 17
- a. Yes.
l l b. The results of the referenced safety testing as a whole l
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have been considered in the Project's continuing environment analysis activities. The overall result of the safety testing is to reduce uncertainties in (if not to actually reduce) calculated environmental impacts.
INTERROGATORY 22 National Academy of Science, Ihg Effects DD Pooulations 21 Exoosure 12 L2M Levels 91 Ionizina Radiation (National Academy Press 1980) (BEIR III Report) (Contention ll);
RESPONSE 22
- a. Yes,
- b. Data in BEIR III Report is used in Section 2.8 of the CRBRP ER to assess both the radiological annual dose rates and the 50 year dose commitments resulting from nuclear weapons test.
INTERROGATORY 24 Revisions to ORIGEN Code since April 25, 1977 (Contention 11);
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RESPONSE 24
- a. No.
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- b. Not applicable.
l INTERROGATORY 36 New NRC regulations on physical security (10CFR Subsection l
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73.55, " Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage) '(Contention 4);
RESPONSE
- a. Yes,
- b. The CRBRP must meet the NRC requirements specified in 10CFR Part 73. This requirement will be reflected in Amendment XIV to the Environmental Report.
INTERROGATORY 37 Department of Energy, Nuclear Proliferation and Civilian Nuclear Power; ReDort gf tha Nonoroliferation Alternative Systems Assessment Procrams (DOE /NE-0001/7) (June 1980)
(Contention 4);
RESPONSE 37
- a. No.
- b. Not applicable.
INTERROGATORY 39 l
Recent GAO reports concerning safeguards and physical security (Contention 4);
- a. " Security at Nuclear Powerplants -- At Best, Inadequate" (4/7/77);
- b. Unclassified summary of a classified report entitled,
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" Commercial Nuclear Fuel Facilities Need Better ;
Security" (5/2/77); '
RESPONSE 39
- a. Yes,
- b. Reviewed to ensure all appropriate issues are addressed.
INTERROGATORY NEW 442 ICRP 26 and 30:
RESPONSE 42 Recommendations of ICRP 26 and 30 were used in ER Section 5.2 ia calculating dose commitments to human beings due to release in liquid effluents. The tables generated by Dunning et al of ORNL were applied to CRBR's conservative release estimates.
Dunning's tables employs all the parameters of 1CRP 26 including contributions from specified source organs plus the systemic activity residing in the rest of the body; cross irradiation due to penetrating radiation is incorporated into the tables.
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UNITED STATES OF AMERICA NUCLLAR RECULATORY COMMISSION In the Matter of '
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U. 5. DEPARTMENT Of ENEP.GY. ,
DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION, )
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and )
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TENNESSEE VAll.EY AUTHORITY )
'ArFICAVIT OF RAYMOND L. COPELAPiD
.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 authoriled to Snswer In.tcr-rogatory VII-4 in the Eighteenth Set of Interrogatories.
- 2. That the above-rnentio'ned and attached answers are true and cor-rect to the best of his knowledge and belief.. ,
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SUBSCRIBE nd SWORN to before.me this /17y of May,19B2 J .. W U/L' Notary Public t
fly Commis:ica Expires April 26,1954
UtilTED STATES OF AMERICA NUCLEAP REGULATORY COMMISSION In the Matter of )
U. S. DEPARTMENT OF ENERGY, DOCKET NO. 50-537
)
PROJECT MANAGEMENT CORPORATION, )
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and )
)
TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF HENRY B. PIPER Henry B. Piper, beina duly sworn, deposes and says us follows:
1 That he is e:nployed as Chief Licensing Brance Public Safety Division, CRERP Project, and that he is duly auth0rized to answer Inter-rocatories 1-11. VII-1, VII-3, VII- 5, VIII-9 and VIII-10 in the Fighteenth Set cf Interrogatories.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.
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/ Henry B ,iper y ' ~
SUP.5 CRIB r and SWGRN to before me this /f _ ay of May,'1982.
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fly CcTrIission E>p.tres Apr;; 28,19M
UNITED STATES OF IMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
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U. 5. DEPARTMENT OF EfiERCY ) DOCKET tio. 50-537
)
PROJECT MAfiAGEMENT CORPORATION, )
and
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TEf1NESSEE VALLEY AUTHORITY )
AFFIDAVIT OF WENDALL W. OGG Wendill W. Ogg being duly sworn, deposes and says as follows:
.l. That he is employed as huclear Engineer, Public Safety- ,
Division. LEBkP Project, and that he is duly authorized to answer Inter-regatories VIII-22. and Vill-C'2 of the Eighteenth set of Interrogatories.
- 2. That the above mentioned and attached answers are true and correct to the best of his knowicdge and belief. .
gm ' - a Wendall W. Ogg j -
SUBSCRIt:ED and SWCF.fi to before me this /1 -g_(c.y of May,1982 A / , e e l um ygie- -
O vy emesis wco;o n. w
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UNI'IID SI7 DES OF AMERICA IUCLEAR REGIA 70R1' CCEMISSION In the matter of )
UNITED STATES DEPAR'IMD7f 0F DECI)
DOTST ?O. 50-537 PROJECT PRWID'Eh" (DRPOSATION )
'IDDESSEE W.:1.Y NJnDRITY )
?? Par.VT'P G' PA'IL w. DICKmN, JR.
Paul W. Dickson, Jr. being duly sworn, deposes and says as follows: .
- 1. That he is eTplctfed bi Westinghouse I:lectric Corporation as
- 7echn2 cal Director, Clinch River Breeder Reactor Project, P. O. Box W, Oak Ridge, Tennessee.
- 2. That he is dJ1y authori?.ed to answer the Interecgatories nu:d;ered VIII-8,11,16, and 17 in IGCC'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.
R../ %
- Z.-i.4...
. g7 Signature) -
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Subscribed and swo:n to before ne this l'I day of byp,1982.
8 lbsA?Wf w
Mi Ccmission expires ,
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Pc.blic fi9 Ocw..M! .- E <.f r: tyd 25,195.* -
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- YY UNITED STATES OF AMERICA s-WUCLEAR REGULATORY COMMISSION f.
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.k'
.g
,) g In the matter of 9
,)
Department of Energy DOCXET NO. 50-537 ,if g-PRNECT MANAGEMENT CORPORATION and,)
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,) ~.
s TENNESSEE VALLEY AUTHORITY w fa' AFFIDAVIT OF John R, Longenecker, being duly sworn, deposes and says fj S
[, ,
as follows: L
- 1. That he is employed as Manager, Licensing and Environmental y
Coordination, Office of Nuclear Energy, U.S. Department of (
Energy, and that he is duly authorized to answer interrogatory E numbers VII.1. VII.3, VII.4, VII.5, VIII.36, VIII.37, and V11I.39 P4 3..
si in the eighteenth set, !
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- 2. That the above-mentioned and attached answers are true and r3 F-correct to the best of his knowledge and belief.
I ' I k . Digte. - Signat e
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g SUBSCRIBED and SWORN to befo're me this /'T _ day of (f :J.A ,_, 1982. @ fl.' ? j
)
ra
' Notar
- 8. QL.-
ub'lic lc j l, My commission expires [.. i' / ,19J,L l l! C. ..) I w
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l In the matter of .) Department of Energy ,) DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,) TENNESSEE VALLEY AUTHORITY ,) AFFIDAVIT OF Roy F. Garrison, being duly sworn, deposes and says as follows:
- 1. That he is employed as Manager, Transportation Operations and Traffic, U.S. Department of Energy, and that he is duly authorized to answer NRDC interrogatory number V.8a. in the eighteenth set.
- 2. That the above-mentioned and attached answer is true and correct to the best of his knowledge and belief.
> c- (
' ~, Kh 4% ,
' T Signature SUBSCRIBED and SWORN to before me this / o day of /n p a , 1982.
n af>b> L'( D $3 r}st Notary >Public My Commission expires , 19_. PATR' CIA' G, CUA>,-- , ND* A g r '.te '.*c e s-m . . . .. . . , )
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1DTX.'; R.'.'Le:7. *;' y* ' N.y Cer..;a::n S ' pic s J.',1, e , 2
1 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION
)
In the Matter of )
)
UNITED STATES DEPARTMENT OF ENERGY )
)
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
)
TENNESEE 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 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)
,. j N Atomic Safety & Licensing Appeal Board l 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) The Honorable William M. Leech, Jr., Attorney General The Honorable William B. Hubbard, Chief Deputy Attorney General The Honorable Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General , 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire 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)
**Dr. Thomas Cochran Ms. Barbara A. Finamore 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 Ms. Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006
3-Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esquire dA Warren E. Bergholz, Esquire U. S. Department of Energy 1000 Independence Avenue, S.W. Room 6B-256 Washington, D.C. 20585 (4 copies)
**Eldon V. C. Greenberg, Esquire 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 N
eorge C Edgar ' / Attorney for Project Management Corporation
*/ Denotes hand delivery to 1717 H Street, N.W., Washington, D.C.
l l **/ Denotes hand delivery to indicated address. l ***/ Denotes hand delivery to 4350 East-West Highway, Bethesda, ! Md. l ****/ Denotes hand delivery to 7735 Old Georgetown Road (Maryland National Bank Building), Bethesda, Md. May 20, 1982 mw awn ~ m- - - - - - . - - - - - - - , - _ - - - _ _ _ _ _ _ _ - - _ - -}}