ML20054B773
| ML20054B773 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/15/1982 |
| From: | Bergholz W, Edgar G ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP. |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8204190186 | |
| Download: ML20054B773 (14) | |
Text
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. April 15, 1982 l'[p .r
'02 pa y UNITED STATES OF AMERICA 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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TENNESSEE VALLEY AUTHORITY ) , o3 \19 / 9
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(Clinch River Breeder Reactor ) 6 g g Plant) ) ' f,g..4
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APPLICANTS' FOURTH SET OF % ^ #
INTERROGATORIES TO INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC. 4/
/fUi g p'g AND THE SIERRA CLUB Pursuant to 10 C.F.R. S 2.740b and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy, Project Management Corporation, and the Tennessee Valley Authority (the Applicants) hereby propound the following interroga-tories to the Intervenors' , Natural Resources Defense Council, Inc. (NRDC) and the Sierra Club, to be answered fully, within 14 days in writing and under oath, by one or mc,re representatives of NRDC or the Sierra Club who have personal knowledge of the matters therein.
D503 J 15 DOCK off 05a7 PDR l
Each answer to an interrogatory shall be preceded by a copy of the particular question to which the answer is responding.
In addition to providing the direct answer to each interrogatory, where applicable, please provide the following:
(a) Identify all documents and studies, and the particular parts thereof, relied upon by Intervenors, now or in the past, which serve as the basis for the answer. In lieu thereof, at Intervenors' option, a copy of such docu-ment and study may be attached to the answer.
(b) Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (a) . In lieu thereof, at Intervenors' option, a copy of each such document and study may be attached to the answer.
(c) Identify by name, title and affiliation the primary Intervenor employee (s) or consultant (s) who provided the answer to the question.
(d) Identify the expert (s) if any, which Inter-venors intent to have testify on the subj ect matter ques-tioned, 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 Intervenors have in fact identified the
expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.
Finally, in responding to interrogatories related to Contentions 1, 2 and 3, Intervenors may defer their response until after an LWA partial initial decision for any interrogatory raising matters which, in Intervenors view, are not necessary to a decision on Applicants' LWA request, by so indicating in the response.
Interrogatories
- 1. For each admitted contention:
(a) Please identify any documents, by author, title, publisher and date of publication which have come to the attention of Intervenors since this proceeding was suspended in 1977 and which Intervenors intend to rely upon, in preparation for or at the hearing in this proceeding.
l (b) Please identify the expert (s), if any, who Intervenors intend to have testify on the subject matter of the contention and state the qualifications of each expert in terms of education and/or experience.
(c) Please identify any ongoing research or analysis of which Intervenors are aware which relate to the subject matter of the contention.
- 2. For Contention 1 (Old 2)
(a) Please identify all CDA initiators, other than anticipated transients without scram, for which NRDC believes that a demonstration must still be made that their probability is sufficiently low to enable CDAs to be excluded from the envelope of DBAs.
(b) As to each "CDA initiator" identified in response to 2(a) above, including anticipated transients without scram, please provide a description of the minimum scope and detail of reliable data (including analyses, tests, data, compilations thereof, facts, opinions, or assumptions) which you consider to be necessary and suffi-cient to demonstrate that such "CDA initiator" has a 1
sufficiently low probability that it may be excluded from the design bases for CRBR.
l (c) Please identify and describe in detail all
" credible failure modes" which you believe are not encom-l passed in the proj ected data base to be used in the l
l reliability program.
I l (d) As to each " credible failure mode" iden tified in response to 2(c) above, describe in detail the data
necessary to encompass such " credible failure mode" in the proj ected data base.
(e) Please identify and describe in detail all
" human elements" which you believe are not encompassed in the proj ected data base to be used in the reliability program.
( f) As to each " human element" identified in response to 2(e) above, describe in detail the data necessary to encompass such " human element" in the proj ected data base to be used in the reliability program.
(g) Please describe specifically the "implica-tions of the TMI-2 accident, particularly regarding the effects of human error in failure to scram"- in relation to the CRBR.
- 3. For Contention 2 (Old 3)
(a) Please identify and describe in detail each specific element of the analyses of CDAs and their conse-quences by Applicants and Staff which you consider to be inadequate for licensing the CRBR. The answer to this I
interrogatory must include a detailed description or explanation of the inadequacies in the analyses.
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-/ See Intervenors New Information Relevant to i Intervenors' Contentions at 4 (March 12, 1982).
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(b) Please identify and describe in detail each specific element of the analyses of CDAs and their conse-quences by Applicants and Staff which you consider to be inadequate for performing the NEPA cost / benefit analyses.
The answer to this interrogatory must include a detailed description or explanation of the inadequacies in the analyses.
(c) Please identify and describe in detail each specific element of the analyses of CDAs and their conse-quences by Applicants and Staff which you consider to be inadequate for demonstrating that the radiological source term for CRBRP would result in potential hazards not excluded by those from any accident considered credible.
The answer to this interrogatory must include a detailed description or explanation of the inadequacies in the analyses.
(d) Please identify all changes in reactor vessel and core design which have not been included in Applicants' accident modeling, and which you believe should have been so included.
(e) Please describe in detail the specific tech-nical bases for Intervenors' contention that "the radiologi-cal source term analysis in CRBRP site suitability should be derived through a mechanistic analysis."
(f) Please describe in detail the specific tech-nical bases for Intervenors' contention that " radiological source term analysis should be based on the assumption that CDAs (failure to scram with substantial core description) are credible accidents within the DBA envelope, should place an upper bound on the explosive potential of a CDA, and should then derive a conservative estimate of the fission product release from such an accident."
(g) Please identify and explain specifically why you believe the radiological source term analysis has inadequately considered (1) the release of fission products and core materials , and (2) the environmental conditions in the reactor building created by release of substantial quantities of sodium. The discussion of deficiencies in the analysis must include any analytical standards which have not been met.
(h) Please list any fission products and core materials other than halogens, iodine and plutonium, which must be considered in the radiological source term analysis.
(i) Please describe in detail the environmental conditions in the reactor containment building created by the release of substantial quantities of sodium which you believe were not adequately considered in the radiological source term analysis.
(j) Please describe in detail the inadequacies in the Applicants' or Staff's analysis of containment design.
- 4. For Contention 3 (Old 4)
(a) Please identify and describe in detail all accidents associated with core meltthrough following loss of core geometry and sodium-concrete interactions which you believe have not been adequately analyzed. The answer to this interrogatory must include a detailed description or explanation of all bases for Intervenors' assertion that such accidents have not been adequately analyzed.
(b) Please identify and describe in detail all human errors which can initiate, exacerbate or interfere with the mitigation of CRBR accidents and which you believe have not been adequately analyzed by Applicants or Staff.
The answer to this interrogatory must include a detailed description or explanation of all bases for Intervenors' assertion that such human errors have not been adequately analyzed.
(c) Please identify and describe in detail any accident possibilities of greater ' frequency or consequence than the accident scenarios analyzed by Applicants and Staff.
(d) Please furnish a copy of the January 27, 1982 letter from Richard Shikiar to Thomas Cochran to which
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_9-Intervenors refer on page 28 of their Revised Statement of Contentions and Bases.
- 5. For Contention 5 (Old 6)
(a) Please identify and describe in detail the population characteristics of the CRBR site which you consider sufficiently unfavorable that an alternative site should be selected.
(b) Please identify the several alternative sites which you consider to have population densities which are more favorable than the population density of the CRBR.
(c) As to each alternative site identified in response to 5(b) above, describe in detail the population characteristics of that alternative site.
(d) Please list all "other proposed fuel cycle facilities" referred to in Contention 5(b) .
- 6. For Contention 11 (Old 8)
(a) Please describe in detail the approach which you believe should be used in establishing guideline values for permissible organ doses.
(b) Please identify all "important organs" which you believe should be considered in establishing dose guideline s .
(c) Identify and describe in detail all "new knowledge" which you believe should be considered in estab-lishing dose guidelines.
I (d) Please explain specifically the basis for your assertion that Applicants and Staff have not adequately assessed the residual risks associated with genetic effects from radiation exposure in compliance with existing NRC standards. The answer to this interrogatory must include a detailed description or explanation of Intervenors' view as to why the assessment is not adequate.
(e) Please identify and describe in detail the basis for your assertion that Applicants and Staff have not adequately assessed the residual risks associated with induction of cancer from the exposure of plant employees and the public in compliance with existing NRC standards.
- 7. For Contention 8 (Old 14)
(a) Please identify and describe in detail the unavoidable adverse environmental effects associated with the decommissioning of the CRBR which you believe have not been adequately analyzed. The answer to this in terroga tory must include a detailed description or explanation of the specific elements of the analyses which you assert are inadequate and the bases for that assertion.
(b) Please identify and describe in detail the costs associated with the decommissioned CRBR which you assert are not adequately assessed in the NEPA cost / benefit l
balancing of the CRBR. The answer to this interrogatory must include a detailed description or explanation of the
I specific elements of the analyses which you assert are inadequate and the bases for that assertion.
(c) Please state whether it is your view that the CRBR FES is inadequate due in part to recently discovered omissions in regard to the subj ect matter of contention 8 and, if so, identify and describe all such "recently discovered omissions."
(d) Please state whether it is your view that the CRBR FES is inadequate for reasons other than "recently dis-covered omissions and, if so, identify and describe all such inadequacies in the CRBR FES.
(e) Please identify specifically any and all neutron activation products, other than nickel 59 and niobium 94, which you assert have not been adequately analyzed for the decommissioning of the CRBR and/or which you believe must be so analyzed.
Respec tfully submitted ,
'eo r L. Edga Attorney for Proj ect Management Corpora tion Warren E. Berghol /
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Attorney for the Department of Ener y
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'82 TP215 P4 :40 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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TENNESSEE VALLEY AUTHORITY )
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(Clinch River Breeder Reactor Plant) )
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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 l Washington, D. C. 20545 ,
,
- Daniel Swanson, Esquire I *Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (2 copies) l
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- Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Co= mission 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 Co= mission Washington, D. C. 20545 (3 copies)
William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 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 Barbara A. Finamore, Esquire Natural Resources Defense Council 1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 (2 copies)
Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006
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Lawson McGhee Public Library 500 West Church Street
. Knoxville, Tennessee 37902
, William E. Lantrip, Esq.
Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq.
Warren E. Bergholz, Jr., Esq.
U. S. Department of Energy 1000 Independence Ave., S. W.
Room 6-B-256, Forrestal Building Washington, D. C. 20585 (2 copies)
- Eldon V. C. Greenberg Tuttle & Taylor j 1901 L Street, N. W., Suite 805 i Washington, D. C. 20036 Commissioner James Cotham Tennessee Department of Economic !
and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 sM "
Geo W L.)i:ff,ar V Attorney for Project Management Corporation DATED: April 15, 1982
- / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
- / Denotes hand deliverv to indicated address.
- / Denotes hand delivery to 4350 East-West Highway, Bethesda, Md.
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