ML20054C706

Updated Response to Twelfth Set of Interrogatories. Certificate of Svc Encl

ML20054C706
Person / Time
Site:	Clinch River
Issue date:	04/20/1982
From:	Copeland R, Kripps L JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
To:	National Resources Defense Council, Sierra Club
References
NUDOCS 8204210528
Download: ML20054C706 (74)

Text

' 4/20/82

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3 UNITED STATES 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 ) .g ,

(Clinch River Breeder Reactor Plant)) f

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, G,. f. .S3 APPLICANTS' UPDATED RESPONSE J"i 8 TO INTERVENORS', .\U - N NATURAL RESOURCES DEFENSE COUNCIL, INC. ~ 'br s 6' AND SIERRA CLUB, TWELFTH SET OF INTERROGATORIES TO THE APPLICANTS Pursuant to 10 CFR l 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 update their January 6,1977 responses to Intervenors', Natural Resources Defense Council, Inc., and the Sierra Club, Twelfth Set of Interrogatories to the Applicants, dated December 18, 1976.

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Interrogatory I in light of the requirements of NEPA to consider alternatives not within1he power of the ogency to implement, justify the failure of ERDA to consider land within five areas identified in its November 18,1976, (formal submittal on citernative sites (Section 2.1))

as withdrawn.

Response

Five areas, Gateway Mining District, Slick Rock Mining District, Land 9/ithdrawn No. 9 (Colorado), No.10 (Utah), and No.12 (New Mexico) were port of a listing compiled by the General Services Administration of all U.S. Government real property in the custody of ERDA. The terminology " land withdrawn" refers to the lands being withdrawn from the public domain in the late 1940's and early 1950's for exploration by the Government.

Upon further investigation, these arcos were eliminated from consideration as alternatives for the LMFBR Demonstration Plant because ERDA possesses only the mineral rights together with such use of the surfoce os is required to exploit them (except for 690 ocres scattered among 37 potented mining claims which are held by ERDA in fee). In odd tion, proctically all of these lands are currently under lease to private companies and individuals for the production (eventually) of uranium / vanadium bearing ores.

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. Interrogatory 2

- With respect to the Rocky Flats site, describe in detail (or ottoch_a copy) of the certification to the State of Colorado with respect to excluding future facilities.

Response

The certification to the State of Colorado was mode in the Environmental Statement for the Land Acquisition of property surrounding the Rocky Flats Plant (WASH-1518, dated April 1972). A copy of WASH-1518 will be mode available for inspection and copying. */

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Applicants have not furnished copies of or made available for inspection and copying those documents referenced in this response whi ch were previously referenced and available pursuant to the Applicants' January 6, 1977 Response. Documents referenced for the first time in this updated response will be made available upon request, fl

. Interroootory 3

- What are the "strmg political issues" involved in piping water from the west slope of the mountains to the Rocky Flats site?

Response

The political issues are not related to the Rocky Flots site itself. The issses involved in diverting odditional water from the western area of Colorado to the fror.t range area are:

a. The limited availability of water for many increasing demands in the State. See Enclosure I for a letter from the managu of the Denver Water Department to William M. Lamb, Manager and Contracting Officer of the ERDA, Rocky Flats Area Office,

b. Transport of water from the western part of Colorado where it is needed for ogriculture and natural resource development to the front ronge area of Colorado which is a rapidly growing area. See the enclosed newspoper articles (Enclosure 2).

c. The impact of collecting and transporting water in or through designated wilderness creas and the impoet on recreational use of the water. See the enclosed newspoper articles (Enclosure 2).

fl Interrogotory 4 What are the factors which were used to determine that the Rocky FJots site had no compelling site advantages over the Clinch River site and what dato exists with respect to each factor?

Response

The unovallobility of the buffer zone for construction of nuclear facilities and the interference with the plant mission which would occur should a demonstration breeder reoctor be constructed in the original plant site area eliminated consideration of the Rocky Flats site. The lock of ovalloble water for cooling also makes location of the demonstration facility at the Rocky Flats site improctical. No further analysis of the Rocky Flats site was done or worronted based on the obove. The statement that there were "no compelling site odvantoges" was intended simply to reflect the obsence of any known foctor regarding the Rocky Flots site which would outweigh the above basis for eliminating it.

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- Interrogatory 5 1

Explain how the choice of the Clinch River site is consistent with 4he guidance of Regulatory Guide 4.7 and explain why sites with lower population density are not preferable on safety grounds.

Response

NRC in Regulatory Guide 4.7, " General Site Suitability Criteria for Nuclear Power Stations" provides guidelines "to indicate considerations that should be addressed in the initial stoge of the site selection process to identify potential sites for nuclear power stations." The information relating to the considerations identified in Regulatory Guide 4.7 are discussed in the CRBRP PSAR and/or ER as follows:

Geology / Seismology - PSAR Section 2.5 " Geology and Seismology" and ER Section 2.5 " Geology".

Atmospheric Extremes and Dispersion - PSAR Section 2.3, " Meteorology" and ER Section 2.6 " Meteorology", discuss general CRBRP site meteorology including calculation of x/O's. ER subsections 5.l.8 and 5.4.5 oddress non-rodiological atmospheric considerations such as cooling tower drift, fogging, etc.

Population Considerations - ER Section 2.2 " Regional Demography, Land i

I and Water Use" discusses present and projected resident and transient population surrounding the CRBRP site. PSAR Section 2.1 defines the

! CRBRP exclusion boundary and low population zone.

l Hydrology (flooding, water ovallobility, ed water quality) - PSAR Section 2.4 ' Hydrologic Engineering", and ER Section 2.5 " Hydrology".

Ecological Systems and Biota -

ER Sections 2.7 " Ecology", 4.0

" Environmental Effects of Site Preparation, Plant and Transmission Facilities Construction", and 5.0 " Environmental Effects of Plant Operation".

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Interroootory 5 Response (continued)

Land Use and Aesthetics - ER Sections 2.2., " Regional Demography, Land and Water Use", and 3.1 " External Appcorance".

Industrial, Military, and Transportation Focilities - PSAR Section 2.2

" Nearby industrial, Transportation, and Military Focilities".

Socio Economics - ER Section 8.0 " Economic and Social Effects of Plant Construction and Operation" and Appendix C.

Noise - ER subsections 4.l.l.7, 5.l.8.4, and 5.7.2.3.

The information presented in the CRBRP ER and PSAR clearly stows that the Clinch River site is consistent with the intent and guidelines of Regulatory Guide 4.7 and is a suitable site for the LMFBR Demonstration Plant.

With regard to population density, if it were the sole siting criteria for the LMFBR Demonstration Plant, it would be true that the site with the lowest population density would be the preferred site. However, population density is mly one of many chorocteristics which must be considered in on analysis of alternate sites. Upon consideration of all pertinent factors including program and project objectives, the Clinch River site is the preferred alternative.

fI Interrogatory 6 Explain in detail how, in rejecting a site near the Paducob Goseous Diffusion Plant and the Portsmouth Goseous Diffusion Plant, the judgment was made that one-half mile represents the critical proximity between a LMFBR ond a gaseous diffusion plant and opply the specific criteria to the CRBR site and other nuclear facilities now located or planned to be located within the Ook Ridge site.

Response

in the Appliconts' offernative site analysis of ERDA land at the Paducah Caseous Diffusion Plant and the Portsmouth Coseous Diffusion Plant, proximity to the existing facilities was only one of several factors used to conclude that neither site should be considered further os m alternative site for the LMFBR Demonstration Plant. At Portsmouth there is insufficient land available for siting the LMFBR Demonstration Plant especially when considering the odd-on plant being built there. At Paducch although there is potentially sufficient land available, the LMFBR Demonstration Plant would be located within the existing buffer zone and would be less than 1/2 mile from the main plant complex. The I/2 mile, is not, and should not be implied to be the critical proximity between on LMFBR and a gaseous diffusion plant, but merely the distance which would result from siting the LMFBR Demonstration Plant at the Paducch site. It was judged that this close proximity, which could result in conflictir.g security, heoith, safety, and possibly environmental problems was undesirable. Based on a review of nuclear facilities now located or planned to be located in the general vicinity of the CRBRP, (OSAR 2.2), there would be no such conflicts involved in siting the demonstration plant of the Clinch River site due to the relative distance of these facilities from the Clinch River site.

i l fl Interrogatory 7 Describe in detail what is meant by the phrase " greater seismic probobilities in the Podocah area os compared to the Ook Ridge area by a factor of approximately two" ond specifically relate your answer to the calculation of the SSE and the OBE for each site os those concepts are defined in 10 CFR Port 100, Appendix A.

Response

The largest earthquake intensity at Paducob, Kentucky, was caused by the New Madrid, Missouri earthquakes of 181I and 1812. These earthquakes, centereri about 80 kilometers from Paducob, produced on intensity of X(MM) of the site (see Figure 1). However, due to the proximity of the Poducoh site to the IX(MM) band, o IX(MM) intensity was used since this would prod.,ce the lowest (hence most favorable) occeleration for comparison purposes. Using the Modified Neumonn acceleration - intensity relationship, on IX(MM) earthquake will produce on acceleration of 0.53g, which is greater os compared to the Ook Ridge area by a factor of opproximately 2. Consistent with 10 CFR 100 Appendix A, Section V.o.2, the OBE occeleration would be half that of the SSE, or opproximately 0.279.

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interrogatory 8

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What were the assumptions used crid calculations mode in concluding that the peak occeleration value of 0.7Sg was opprcpriate for the Nevada Test Site? Relate your answer to the calculational requirements for SSE and peak occeleration values used in 10 CFR Port 100, Appendix A.

Response

The basis for the 0.75g peak occeleration value of the Nevada Test Site con be found in Reference 1. This report determined that the highest acceleration at the site would be produced by the Mine Mountain fault, one of the active faults on the site. Based on geological evidence, the maximum earthquake associated with this fault would have o mognitude of about 7. Consistent with 10 CFR 100 Appendix A, Section V.o.l.I, and using the attenuation curves in Reference 2, o minimum value of 0.7 9 or f the Nevada Site would result.

These references will be mode available for copying.

l. Rogers, A.M., Perkins, D.M. and McKeown, F.A., "A Preliminary Assessment of the Seismic Hazard of the Nevodo Test Site Region,"

U.S. Department of the Interior, Geological Survey Administrative Report, October 1976.

i I 2. Schnobel, P.B. and See, H.B., " Accelerations in Rock for Earthquakes in t

the Western United States," Seismol. Soc. American Bul. 63,

p. 501-516,1973.

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interroootory 9 What factors were used in rejecting the buffer zone of the Feed Maf Center, Fernold, os a site for the LMFBR demonstration plant and wh respect to each of these factors?

_ Response The factor which eliminated the site of the Feed Materia Fernald, Ohio, from further consideration as on alternate site for the L Demonstration Plant was land availobility. The industrial plant complex center of the 1080 Demonstration Plant. ocre site and there is insufficient land to site the Interrogatory 10 Locate the proposed Exxon Reprocessing Plant at Ook Ridge with reference to the CRBR site and explain why its presence within the Ook Ridge site does not create problems comparable to those involved with co-location of the LMFBR demonstration with other ERDA-owned facilities such as gaseous diffusion plants, feed materials production centers, etc.

Response

The proposed Exxon Nuclear Focility at Ook Ridge hos been concelled.

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fI Interroootory iI Provide copies of all written communications prepared on or offer January 1,1976, between Applicants and any persons involved in preparing Exhibits 1-111 of Applicants' November 18, 1976, submittal on alternative sites with respect to the contents of those Exhibits and copies of all memorondo of oral communications between the some persons, during the some time period and about the some subje::t.

Response

For Exhibit I, the referenced October 28, 1976, memorandum from E.S. Beckjord to H.E. Roser, et al., is enclosed (Enclosure 3). Also enclosed (Enclosure 4) is a copy of the further guidance which was informally provided to the ERDA Field Offices and the ERDA Division of Military Application regarding consideration of ERDA lands os alternatives for the LMFBR Demonstration Plant. Otherwise no written communication or memorondo of oral communications on or offer January 1,1976, exists between the Applicants and the persons involved in preparing Exhibits I,11, or Ill.

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. Interrogatory 12

. In light of the current arrongement for the CRBR with ERDA providing most of the funds and owning the facility, why is the Honford site not feasible for co-location of the LMFBR demonstration? In particular, explain why current financial arrongements and utility expertise input connot be readily utilized for siting at Hanford.

Response

See Sections C-2-B and D-3 (pgs. 21-25, 31-33 respectively) from Enclosure I to the December 29,1976 letter A.R. Buhl to R.S. Boyd and Section 3.0 from Attochment 2 to the February 12, 1982 letter J.R. Longenecker to P.S. Check for this response.

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. Interrogatory 13 Explain why the LMFBR demonstration plant is not sufficiently important to take precedence over WPPSS plans for additional nuclear facilities.

Response

WPPSS has been unwilling in the post to assume the role which wou!d be required, and has indicated that the some posture holds true today (see ottochment i to December 29,1976 letter A.R. Buhl to R.S. Boyd and the enclosed February 16, 1982 letter R.M. Greening, Jr. to W. Rolf (Enclosure S)). Since DOE has no authority to compel WPPSS to change its stated position, it is not possible to identify any means by which DOE could change WPPSS's stated priorities.

fI Interrogatory 14 Compare the level of technical expertise and financial resources available in the Pacific Northwest and available within the TVA system in light of the projected expansion of nuclear reactors in both areas.

Response

The Appliconts have not performed detailed comparative analyses of the levels of technical expertise and financial resources available in the Pacific Northwest and within the TVA system. Nevertheless, information available to the project indicates that within utility systems directly sponsoring the project - TVA, Commonwealth Edison - that between the TVA system and Commonwealth Edison a total of $33,114,200 has been pledged to the project, while the Northwest Utilities have pledged some $14,491,994.

Whether TVA and Commonwealth Edison would or could transfer all or any part of their commitment to onother site within or outside the TVA crea is a matter of pure speculation, depending as it would upon as yet undefined contractual arrangements and congressional opproval. Likewise, it would be pure speculation to assume that the contributing utilities would be in a position to continue their support if another site were chosen. Even if it were assumed the contractual and legislative arrangements could be mode to move the project, the Northwest Utilities would not be in as good a position as TVA and CE to provide technical expertise to the project because of their lock of prior porticipation.

,TVA and CE have contributed opproximately 390 mon years of technical effort to the

- pro? x:t, while the Northwest Utilities to date have contributed none. This translates into boctground experience important to ochievement of project objectives which is not readily ochievable by others at this date.

fl Irterrogatory IF '

in comparing the CRBR site with the Honford, Idaho, and Savannah River sites, explain how the advantoges and disodvantages of each site were quantified for comparison. For instance, what weight was given to rnere favorcble atmospheric conditions and what weight was given to less advontogeous socio-economic impacts?

Response

While it is difficult to precisely quantify the advantages and disodvantages of each site, upon consideration and balancing of all relative costs, benefits, effectiveness, and risks associated with Honford, Idaho, Savannah River, and Clinch River, it is clear that Clinch River remains os the preferred plant location. Additional information supporting this conclusion o,d describing the Appliconts' boloncing of the foreign factors is presented in the December 29,1976 letter A.R. Buhl to R.S. Boyd and in the February 12,1982 letter J.R. Longenecker to P.S. Check.

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Interrogatory 16 How many construction workers will be used in building the CRBR? --

Response

Table 8.2-1 of the Applicants' Environmental Report presents the estimated number of persons required for the construction and operation of the CRBRP. The table breaks down employment by manuals, non-monvols, subcontractors, CRBRP Project Office, controctor support personnel, and operations personnel.

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Interrogatory 17 What skills will be required and how many of each kind of skill will be required?

Response

Below are listed the specific construction craf ts and the peak number of workers needed for each craf t.

Croft Peak Number Ironworkers 495 Carpenters 705 Laborers 805 Steamfitters (Pipe) 800 Electricians 795 Asbestos Workers 120 Operating Engineers 215 Cement Finishers 75 Pointers -

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Interrogatory 18 How many person days will coch person with each skill work during constmetion?

Response

Estimates of person-days for each skill required for CRBRP construction con be obtained by multiplying the craft percentoge provided below by 2.84 million total person-days which is the total labor estimated to be required for CRBRP construction. This total person-days required was computed from the total ccnstruction workforce estimated in ER Table 8.2-1 ond the assumption of 250 person-days per year.

Percentages of Total Construction Croft Workforce Required Ironworkers 10 Carpenters 15 Laborers 17 Steamfitters (pipe) 17 Electricions 17 Asbestos Workers 3 Operating Engineers 5 Cement Finishers l Pointers l Boilermakers 4 Teamsters 2 Miscellaneous 8 t I fl

Interrogatory 19 Where will the construction workers in each skill area come from to build the CRBR and how long will coch group of workers reside in the area?

Response

The Applicants, as port of their socio-economic analysis, have mode estimates of the froction of the total number of persons needed for construction and operation of the CRBRP that will be relocating or migrating into the study creo. The study area is shown in ER Figure 8.l-l. The basis for the estimates is provided in ER Section 8.3.2.1 and the introduction to Appendix C. Section 1.0 of ER Appendix C presents the resulting expected new population in the study creo. Since the socio-economic onalysis of the effects of CRBRP construction md operation is dependent only on the number of individuals, it was not necessory to break down the treatment of construction workers by the various skilled crafts.

As noted in the introduction to ER Appendix C, two estimates of construction worker migration rates have been mode (Condition A and Condition B) in recognition of the possibility of differing degrees of competition for workers from the area work force.

Migration Condition A reflects TVA construction experience and ordinary competition for workers. Migration Condition B reflects this some experience but allows for the possibility that other major construction projects (such as the proposed Koppers Liquifoetion Project) may hire workers from the area labor force at the some time os the CRBRP Project.

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. Are the workers for the CRBR now employed or unemployed? -

Response

The Appliconts do not know whether construction workers required for the CRBRP are employed or unemployed at the present time. The employment picture in the CRBRP study area is discussed in ER Section 8.1.2.2.2.

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Interrogatory 21 If they are employed, what assuronce is there that they will be available to work when needed of the CRBR?

Response

The availobility of construction workers from the study creo for construction of the CRBRP is reflected in the estimated migration rates discussed in the response to interrogatory 19, i

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i Interrogatory 22 1

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if they are taken from other jobs, from where will the workers come to fiu those jobs?

Response

Personnel employed in the CRBRP who leave other jobs will be reploced by their former organization, when and if necessary. To attempt to be more definitive would require undue speculation.

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Interrogatory 23

- Answer questions 16-22 on the assumption that the demonstration plant is built at Hanford. At Idaho. At Savonnah River.

Response

The responses to interrogatories 16,17, and 18 concerning the chorocteristics of the construction work force required for the CRBRP are essentially independent of location, and therefore, con be utilized as responses for Honford, Idaho, and Savannah River.

With regard to interrogatories relating to the socio-economic impact of siting the LMFBR Demonstration Plant at Honford, Idaho, or Savannah River, no detailed

' socio-economic analysis has been made by the Applicants. Only at the CRBRP site have the Applicants done a detailed socio-economic assessment of the effects of construction and operation. The general discussion of socio-economics (lobor availability) presented in Sections 2.1.1.9 (Honford), 2.1.2.9 (Savannah River), 2.l.3.9 (Idaho), and summarized in Table I of Attachment 2 of the February 12,1982 letter J.R. Longenecker to P.S. Check

, did not result from any detailed study. The general discussions and conclusions reached l

in the updated alternate site analysis for Honford, Savannah River, and Idaho were based l

on judgments mode offer review of the socio-economic assessments mode for the Skogit/Honford Nuclear Project at Hanford and the Defense Woste Processing Focility at Savonnah River. At Idaho, only the general demography and the information presented on post construction labor forces was reviewed.

Therefore, the Appliconts have no information regarding specific impacts which would be incurred during construction and operation if the LMFBR Demonstration Plant were located at Hanford, Idaho, or Savonnah River.

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Interrogatory 24 Why aren't the workers expected to be used to build other WPPSS nuclear plants available to work on a rotating basis of a LMFBR demonstration plant at Honford similar to the way in which workers are used at multiple plant sites or at possible nuclear parks?

Response

Workers used to build the WPPSS nuclear plants may or may not be able to work on the LMFBR Demonstration Plant. Their availability would depend on the timing of the construction of the WPPSS nuclear plants, the timing of other construction activities on the Honford Reservation and surrounding area, and the timing of the LMFBR Demonstration Plant, if it were to be built at Honford.

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interrogatory 25 How mcriy utility employees will work on operating ts CRBR in its first five years?

Response

Toble 8.2-1 of the Environmental Report estimates the number of CRBR Plant operations employees (all employed by TVA) during the demonstration period,1989 through 1994.

This number includes personnel of the preoperational und startup test teams which will be on board during the first part of the period but are phased out in 1990.

Figure 13.1-1 of the PSAR indicates a total of 344 permanent plant employees. This number does not include that portion of the preoperational and startup test crews that will be present during the early years of the demonstration period.

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interrogatory 26 What skill orcos will be involved and how many workers in each skill areovill be required during the first five years?

Response

Figure 13.1-1 of the PSAR gives a breakdown of the skill oreos, e.g., management, engineers, clerical, operators, craf tsmen, etc. and the number required in each category.

fI Interrogatory 27 I

. How many person-days will each person with each skill work during the first five years of operation?

Response

For the purpose of this response, the permonent plant stoff has been categorized by solary groups - Annual Solary Policy (ASP) and Annual Trades and Labor (AT&L). Those skills which are included in the AT&L ore as follows: laborers, craftsmen, crafts foremen, assistant unit operators, unit operators, instrument mechonics, and instrument mechonic foremen. The remaining skills indicated on Figure 13.1-1 are in the ASP category.

The CRBRP Operation staff will normally be working a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week with a 2 week per year allowance for annual leave. In addition to the normal 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week, overtime and premium pay is included based on the following schedule which was derived from o study of TVA's and Commonwealth Edison's experience during the first five years of plant operation.

Year one (1) of operation 15% of ASP solories 30% of AT&L solaries Years two (2) through five (5) 10% of ASP solaries 20% of AT&L solaries The 344 permanent plant employees con be categorized as follows:

ASP - 219 employees 250 days / year (Normal 40-hour / week schedule) 28 days / year (Equivalent for overtime and premium pay based on on overage of I1% of normal schedule)

,Mys/ year / employee 219 ASP employees x 278 = 60,882 ASP employee days / year 5 years (demonstration period) x 60,882 =

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lnterrogatory 27 Response (continued)

AT&L - 125 employees 250 days / year (Normal 40-hour / week schedule) 55 days / year (Equivalent for overtime and premium pay based on on overage of 22 % of normal schedule) 305 days / year / employee 125 AT&L employees x 305 = 38,125 AT&L employee days / year 5 years (demonstration period) x 38,125 =

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- Interrogatory 28 Where will the workers in each skill arco come from to operate the CRBR?

Response

ER Section 8.3.2.1 estimates that 50% of the operations personnel will be relocating to the study area. The majority of these will be transferring TVA personnel as shown below:

Category Source ASP Managers and Supervisors TVA Engineering TVA; new hires from trade schools Clerical & Nurse New hires; local labor market Public Safety Officers TVA; new hires - local labor market AT&L Instrument Mechanics TVA; trade schools Instrument Mechanic Foremen TVA Shif t Engineers From within the TVA Organization Assistant Shif t Engineers Unit Operators Assistant Unit Operators TVA; new hires from local labor market Craftsmen Local labor market Craf ts Foremen From within the TVA Organization fl

Interrogatory 29 Are these workers now employed or unemployed? --

Response

The present employment status of the personnel who will operate CRBRP is unknown.

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- Interrogatory 30 1

If they are unemployed, what assurance is there that they will be available to work when needed at the CRBR?

Response

There is on orderly schedule for recruiting and training the operations staff.

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Interroootory 31

. If taken from other jobs, from where will the workers come to fill those jobs?

Response

Personnel employed in the CRBRP who leave other jobs will be replaced by their former organization, when and if necessary. To attempt to be more definitive would require undue speculation.

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Interrogatory 32 Answer questions 25-31 on the assumption that the demonstration ptant is built at Hunford. At Idaho. At Savonnoh River.

Response

Estimates of required operational personnel for the CRBRP during the first five years provided in response to interrogatories 25,26, and 27 would be substantially the some at either Hanford, Idaho, or Savannah River. At Hanford, Idaho, or Savannah River, specific responses to interrogatories 28, 29, 30, and 31 are unknown because of the uncertainty concerning a utility operator at these sites. See also the response to interrogatory 23.

i fl Interrogatory 33 Inosmuch as operation of the LMFBR demonstration plant is several years away, why can't a cadre of qualified persons to operate the plant be built up now within any utility system that would be close to Idaho, Savannah River or Honford?

Response

See Section C-2 (pgs 20-25) from Enclosure I from the December 29, 1976 letter from A.R. Buhl to R.S. Boyd and Section 3.0 from Attachment 2 in the February 12,1982 letter J.R. Longenecker to P.S. Check. Also see the response to interrogatory 12.

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lnterrogatory 34 Explain why the advantages of performance within a utility environment would not be fully met by location of the LMFBR demonstration plant at a site where it is connected to a utility grid system and run by utility personnel who until offer issuance of a construction permit were not employees of the utility into whose grid the demonstration plant is connected. In addition, relate your answer to the transfer of TVA employees to WPPSS for use in running the LMFBR demonstration plant within the WPPSS system.

Response

j TVA would not be able to operate the LMFBR demonstration plant within a utility environment of any system other than the TVA System. The personnel necessory to operate any nuclear generating plant goes for beyond the plant staff. TVA employs experts in many fields not associated with plant operations who function in support of the generating plants. It would not be proctical to suggest that TVA would effectively

! support a generating plant in areas removed from the TVA System. The utilities who would need to be involved at the Hanford, Idaho, and Savonnah River sites have stated their unwillingness to assume added commitments to operate the demonstration plant. In addition, see the response to interrogatory 12.

fl Interrogatory 35 Explain how the proposed construction of the Exxon Reprocessing Plant at Ook Ridge will increase the socio-economic problems associated with the construction of the CRBR and compare these impacts to those anticipated at Hanford and Idaho.

Response

The proposed Exxon Nuclear Focility at Ook Ridge has been concelled.

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- Interrogatory 36 Compare steps being implemented or proposed to reduce adverse socio-economic impacts of the CRBR to steps being proposed or that could be proposed to reduce socio-economic impoets at Hanford and Idoho.

Response

The results of the socio-economic assessment of CRBRP construction and operation shows that no adverse impoets are expected. Concerning the socio-economic impact assessment for the LMFBR Demonstration Plant at Honford or idaho, see the response to interrogatory 23.

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l Interrogatory 37 l I

What consideration was given to locating the LMFBR demonstration in the 100 orea at Hanford where the lowest population density exists?

Response

i No specific areo(s) on the Hanford Reservation were considered in the Environmental Report Appendix D, " Supplemental Alternative Siting Analysis for the LMFBR Demonstration Plant" or the update to it provided in Attochment 2 of the letter from J.R. Longenecker to P.S. Check dated February 12,1982.

fI Interrogatory 38

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What weight was given to the lower population density and how was it quantified?

Response

See the response to interrogatory 15.

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i Interrogatory 39 Why can't construction workers now working at the FFTF (which is nearing completion) be shifted to work on the LMFBR demonstration plant in order to reduce any so-called socio-economic impoets at Hanford?

Response

Construction of FFTF has been completed.

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Interrogatory 40 Describe in detail the socio-economic impacts which you believe will occur if the LMFBR demonstration plant is located at Hanford. For each impoet, explain fully the assumptions you used and what events could occur to alter those assumptions.

Response

See the response to interrogatory 23.

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1 Interrogatory 4l l

- What personal knowledge does Richard C. Nyland have of the facts he expressed in his November 10, 1976, letter to Peter Von Nort?

l Response 1 Mr. Nyland served as the Chairman of the Liquid Metal Fast Breeder Reactor Committee under the Joint Power Planning Council (JPPC) which represented a group of 104 public ogencies, S private utilities, and the Bonneville Power Administration in their porticipation with Westinghouse during the Project Definition Phase (PDP) of the LMFBR Program. The JPPC served as the interfoce between the electric power producers and/or distributors and Westinghouse in all PDP octivities including the evoluotion of potential sites for on LMFBR demonstration plant.

Mr. Nyland served as o member of the Senior Utility Technical Advisory Panel (SUTAP) which was formed to advise the Senior Utility Steering Committee (SUSC) and the AEC on the best means for utility porticipation in and support of the technical aspects of the LMFBR Program (which included plant siting). He worked and met with other members of the SUTAP and porticipated in joint meetings with the SUSC.

Mr. Nyland was Special Assistant to the power manager of the Bonneville Power Administration who is involved in regional power planning in the Pocific northwest.

It was through his association with the JPPC and the SUTAP that Mr. Nyland become directly involved with the activities discussed in his November 10, 1976, letter to Peter S. Von Nort; and as a result of this involvement, he has personal knowledge of the facts expressed in the November 10,1976, letter.

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Interrogcier<3 To the extent Mr. Nyland does not have personal knowledge of the facts contained in the letter, how did be obtain those facts? Attoch copies of any written communications he received to verify the facts osserted.

Response

As discussed in the response to interrogatory 41, Mr. Nyland has personal knowledge of the facts contained in his November 10, 1976, letter to Peter S. Von Nort.

fI Interrogatory 43 identify all persons now involved in preparing for construction of the CRBR and persons to be involved in construction and operation of the CRBR who were employees of TVA as of January 1,1974? As of todoy?

Response

As of January 1,1974, eighteen (18) professional TVA employees were involved in preparing for construction and operation of the CRBRP. As of December 23,1976, this figure had risen to forty-three (43) professionals. As of March 31,1982 the number of professional TVA employees involved was twenty-nine (29).

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, ,t interrogatory 144 -'

What percentage of the total number of persons involved in preporing for construction

- and actual construction and operation of the CRBR were TVA employees on January 1,1974, or are TVA employees today?

Response

TVA employees (see response to 43) represented 48%, 40%, and 39% of the total professional employees (TVA, CE, and DOE) assigned to the CRBRP project as of January 1,1974, December 23,1976, and March 31,1982, respectively.

fI Interrogatory 45 is it your position that safeguarding plutonium would be no more effective if the plutonium were produced, reprocessed, fabricated into fuel and reused all within one area, such as Hanford, than if it were produced at the CRBR site and shipped elsewhere for reprocessing and fabrication? Explain in detail the basis for your onswer and all ossumptions relied upon in the answer.

Response

it is the position of the Appliconts that co-location of the various elements mentioned in interrogatory 45 would not offer substantive advantoges for the safeguarding of plutonium. This is true because the transportation of plutonium in fresh fuel operations is the only aspect of fuel cycle safeguards with potentlot for improved effectiveness in the co-location scheme olluded to in the interrogatory. It is the Applicants' position that the transportation of plutonium in the CRBRP fuel cycle is sufficiently effective so that co-location does not provide a significant improvement in effectiveness (see Section 5.7.l.5 frorn the CRBRP fuel cycle information provided in the March 19,1982 letter from J.R. Longenecker to P.S. Check).

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i f1 Interrogatory 46 Why would co-location of the LMFBR demonstration plant with reprocessing and fuel fabricating focilities not involve construction economies, not reduce the number of sites used and not involve improved waste management systems? In your answer, explain in detail the relevance of the fact that this is a demonstration plant and that the reprocessing and fabricating plants are small.

Response

The LMFBR Demonstration Plant is small in comparison with present day nuclear power reactors and will produce only 350 MW(e). There is of present no authorization or oppropriation for construction of an LMFBR fuel reprocessing plant. Any LMFBR fuel fabrication plant would be of a very small scale compared to projected commercial focilities. Therefore, the construction economics potentially existent or improvements in waste monogement systems that could be offered with large fuel cycle Nuclear Energy Centers (NECs) - (one or more commercial sized reprocessing and mixed-oxide fuel fabrication facilities along with several tens of commercial sized LWR's and/or LMFBR's) could not reasonably be expected to be realized for the LMFBR Demonstration Plant even if a coordinated co-location plan could be developed. Although co-location could reduce from three to one the number of sites required, this provides no real environmentol odvantoge.

fl interrogatory 47 i

1 Provide the detailed analysis, including all ossumptions, which forms the basis for your

. conclusion that the number of surfoce penetrations for on underground plant will result in l o leak rate much like that from o containment building in above ground plants.

Response

The analysis presented in Section 2.3.2 of the " Supplemental Alternative Siting Analysis for the LMFBR Demonstration Plant" concluded that underground siting was not a satisfoctory alternative for the CRBRP, and at the best, was not a substantially better olternative. This conclusion was based on the judgment that underground siting offered no substantial improvements in plant safety, reduction of visual effects, or decrease in land required over on above-ground CRBRP. The analysis went on to list several major disodvantages of underground siting which included potential significant increases in plant costs and construction schedules, and several technical problems which as a minimum would require research and development efforts to fully establish the adequacy of the design.

For the above reasons and considering the fact that no engineering design exists for on underground nuclear plant in the U.S., nor hos any been licensed, the Applicants believe that underground siting of the LMFBR Demonstration Plant would not en balance be o reasonably better alternative. Although the Applicants have not performed a detailed analysis to show that leak rates for underground plants would be much like those for containment buildings in aboveground plants, studies have generally indicated that the leak rates for both concepts would be nearly the same. (For example, see the references listed below.) Consequently, underground siting does not appear to offer any significont odvantoges with respect to establishing and maintaining containment leak tightness, and this was one factor leading to the rejection of the underground siting concept.

fl Interrogatory 47

, Response (continued)

. 1 These references will be mode available for copying.

" Underground Nuclear Plant Siting: A Technical and Sofety Assessment",

J.H. Crowley, P.L. Doon, and D.R. McCreath, Nuclear Safety, 15(5) :

519-534 (September-October 1974), and " Nuclear Power Plants in Evocuoted Rock Coverns", R. Kenneth Dodds, Poul H. Gilbert and Stoffon Logergren, Swedish Underground Construction Mission (1976).

Nuclear Sofety 16(4) : 434-435 (July-August 1975). Comments by J.C. Buclin.

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l l fI interrogatory 48 Would underground siting provide safety odvantages in the event of an occident involving core disruption and assuming (1) the currently proposed CRBR design, or (2) o CRBR desip based on the CDA as a DBA? In your answer, discuss the quantity of radioactive releases and the time in which those releases could occur.

Response

The current CRBRP design, which excludes hypothetical core disruptions from the design basis has been evoluoted with respect to such disruptions and subsequent core melting in CRBRP-3 " Hypothetical Core Disruptive Accident Considerations in CRBRP." This evoluotion has demonstrated that the current design provides odequate protection to the health and safety of the public.

The underground siting scheme could provide safety advantages to the extent of reducing airborne radiooctivity from the containment via diffusion through the containment barrier. If such diffusion is controlling, the underground design would provide further attenuMion to the radioactivity released to the atmosphere in that materials penetrating l

the containment barrier would also have to diffuse through the ground cove prior to reaching the atmosphere. However, the controlling release pathway for airborne

! radiooctivity from the containment is normally vio leakoge through containment penetrations and not via diffusion through the containment barrier. At least some of these leakoge pathways would bypass any ground cover. Furthermore, underground designs considered feasible for reactor installation normally would be expected to require more complex penetrations than do surface designs to ochieve the some reliobility.

Thus, the advantage of increased ottenuation due to the ground cover may well be completely offset by the fact that the capability, or even feasibility, of assuring odequate seals for large occess tunnels, and ventilation and cooling water ducts is very questianoble.

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Interrogatory 48 Response (continued)

A principal mechanism assuring protection to the health and safety of the public is the controlled venting of the containment atmosphere offer cm odequate delay period following the initiation of the event. Venting is initiated to control the hydrogen concentration in the containment eliminating the potential for explosive reactions and assuring long-term containment integrity. Locating the plant underground would not eliminate the need for venting to assure containment integrity and consequently the underground option provides no clear odvantoge in this area. Alternately, it could be postulated that with underground siting the control of hydrogen is unneccessary in that if there were o potential for explosive reactions, these reoctions could be safety contained by the ground cover. However, the failure points in the containment barrier following such explosive reactions would most likely be at containment penetrations such as ventilation ducts and occess tunnels. Consequently, there is a clear potential for uncontrolled hydrogen reactions to create direct leakoge paths to the atmosphere in spite of the ground cover provided by underground siting.

Another oreo related to hypothetical core disruptions and important to underground versus surfoce siting is the potential for groundwater interactions. For on underground siting scheme in which the reactor is located below the water table, the potential exists for flooding of the containment in the event of a hypothetical core disruption and subsequent containment failure. This potential for water flooding is clearly a disodvantage because such flooding would increase the potential for sodium-water reoctions and the consequent generation of hydrogen.

For on underground siting scheme in which the reoctor is located above the water table, groundwater interoctions could occur only as a result of containment vessel penetration. If such penetration is postulated, underground siting would have o net disadvantage compared to the current surface design. This is the cose since, at the time of the assumed meltthrough, the molten core material would be nearer to the water table for the underground design and the delay time between molten core-ground water reaction would be less than the corresponding time for the present surface design.

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Interrogatory 48 Response (continued)

Based on this review, it is concluded that no clearcut net advantage exists such that the protection of the public health and safety would be improved by en underground siting design compared to the current CRBRP design.

There is no justification for the consideration of CDA as a DBA. Further, the foregoing ossessment is considered as having covered the maximum advantages that on underground siting could provide.

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Interrogatory 49 Why connot a substantial number of surface focilities otso be placed underground in separate coverns to reduce the number of surfoce penetrations?

Response

Even if the maximum number of facilities were placed underground, there would still be a significont number of penetrations to the surface. These would include, at the least, piping to the ultimate heat sink, connection to transmission facilities, personnel and equipment occess, and ventilation provisions. As stated in the response to 47, these penetrations would result in a leak which would be very nearly the some os on above ground plant.

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Interrogatory 50 Egloin your conclusion that the CRBR occommodates "with conservatism" the turbine missile occident in light of the following statements:

Technical Safety Activities Report (December,1975)

Item Number ll.A.A.5 Problem Definition:

Information in the area of structural response to impacts of turbine missiles is seldom ovoilable if not totally locking. The scfety concerns derived from consideration of occurrence of a missile generated by failure of a turbine have been consistently egressed in almost all the ACRS letters to the Commission recommending issuance of CP or OL licenses during the lost two years. Since there are significont differences between the porometers governing turbine generated missiles and that associated with tornado, the design procedures applicable to 6:nndo generated missiles may not be applicable to protection barrier design ogainst turbine missiles. An emerimental progrom intended to develop design procedures and criteria for use in the protection barrier design against turbine missiles is urgently needed to resolve the outstonding concerns of both the ACRS and the NRC Stoff.

Current Status:

Only limited information related to turbine missiles is available. As o part of the work scope for item II.A.B.1, o preliminary definition for turbine missile emerimental program was planned. However, NSWC could not undertake this task due to lock of ovailable personnel. EPRI has indicated its interest to undertake limited tests designed to evaluate the impoet of turbine missiles on reinforced concrete barriers.

fI Interrogatory 50 (continued) 1

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. Item Number ll.A.A.9 l Problem Definition:

Develop specific analytical procedures for evoluoting global response of concrete forgets subjected to tornado generated missiles, turbine missiles and aircraft impact employing nonlinear finite element models.

Verification of octual test results by these procedures is required.

ACRS April 6,1976, letter to Commissioners item Il-1 Three issues require answers to resolve the turbine missile problem:

(1) The first relates to the oppropriate failure probability value; based on historical failures the probability is about 104 Industry predicts a much lower failure probability based on improvements in materials and design.

To date the ACRS has accepted the more conservative value; (2) The second issue is strongly dependent on turbine orientation with respect to critical safety structures. Strike probabilities from high angle missiles are occeptobly low for single units and may be occeptable for multi-unit plants, depending on plant layout; however, lower angle missiles with non-optimum (tangential) turbine orientation have unocceptobly high strike probobilities; (3) The third issue is one of penetration and domoge of structures housed in the containment. The limited experimental dato pertaining to penetration of large irregularly shaped missiles are not sufficient to determine structural response to impingement of turbine disc segments. Most missile penetration formulas are not relevant to this cose. Some experiments with irregulor missiles might resolve this issue, particularly for older plants with non-optimum turbine orientations.

fI interrogatory 50 (continued)

Response

The CRBRP occommodates with conservatism on occident originating from turbine missiles. This conservatism includes conservatism in the missile ejection probability, estimation of striking probability, and missile penetration probabilities. Discussion of the CRBRP design to protect against turbine missiles and the associated conservatism is given in PSAR Section 10.2.3.

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Interrogatory Si is it your position that the CRBR would not be less likely to be adversely offected by a tornado or a turbine missile if it were underground? Explain your answer in detail, providing all bases, assumptions and data relied upon.

Response

The interrogatory addressed to the Applicants misquotes the Applicants' position. Itis the Applicants' position that the CRBRP would be designed to protect against internal and external generated missiles regardless whether or not the plant was located above ground or below ground.

The CRBRP, as presently designed, is afforded protection ogainst tornado and turbine generated missiles. The design for protection against tornado missiles is discussed in PSAR Sections 3.3 and 3.5. The design for protection ogainst turbine missiles is discussed in PSAR Section 10.2.3. Clearly, however, the design of the CRBRP, if located below ground, would be different to occommodate turbine and tornado generated missiles. An underground plant design could include rock and soil barriers between the turbine hall and other portions of the plant. These barriers provide some degree of inherent protection against domoge from turbine and tornado missiles.

Structures that might be at the surface, however, (e.g., water intoke, cooling towers, switchyard, ultimate heat sink) would not be immune to tornadoes or tornado generated missiles regardless whether or not the main structures were located above or below ground.

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interrogatory 52 Provide all the factual bases and all the assumptions which you rely upon for your conclusion that undergrounding of the CRBR would involve significont increased plant costs ed increased construction schedule and quantify those increases.

Response

Studies of underground nuclear power plant siting hcve indicated higher nuclear power plant costs and longer nuclear power plant construction times. The following table presents the results of several relevant studies:

Underground Siting Costs Cost Source Concept increase (%) Notes Holmes & Norver (1973) Hillside 19-30 Compared to Coastal - Above Ground CDL (Swedish Power Underground 20 Primary reason l Producers)(1975) for undergrounding protection from octs of war Nuclear Plant Siting Underground 5-10 2-1/2 years extra time A Technical and for completion (1 year Sofety Assessment longer octual plant construction time) l fl

1 interrogatory 53 1

Why are the problems of sealing of penetrations from on underground CRBR plant  :

significontly different than sealing penetrations to the containment of the above ground CRBR plant?

Response

Sealing of penetrations in on underground nuclear power plant may be significantly different than sealing penetrations for on above ground plant due to:

a. Larger penetrations for underground plant,

b. Significant external pressures on seals for underground plant, and

c. Difficulty in inspecting / testing sealing of penetrations in underground plant.

References:

Nuclear Safety, 16(4):434-435 (July-August 1975)

Nuclear Sofety, 15(5):519-534 (September-October 1974).

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Interrogatory 54 Why is flooding any more o problem of an underground CRBR plant than at a surface

. CRBR plant located in the flood plain?

Response

Flooding may be a significant problem for on underground nuclear power plant due to more pathways for flooding, particularly for subsurfoce water and failures in condenser cooling water system.

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interrogatory 55 What are the unresolved structural and ground water problems ossociated with the undergrounding of the CRBR?

Response

Unresolved structural and ground water problems for underground nuclear power plants involve seismic design, new power plant layout designs, sealing of penetrations, and large roof spons. It appears that roof spons on the order of 130 to 140 feet would be required for underground nuclear power plants. These are without precedent for permanent underground facilities (the largest span to date is i10 feet as shown in the following table).

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(IAMPttl 0F Ell 5 flat a0Cc CAttem5 manie end tecetten Petaciset dimenstens sect type senerts Peetine. Teseen1a 45-ft seen. S4 f t htsh. 300 ft long phedstone. shale Rock beltsa mesh ead SunIte Itnine 500 ft rett cover Morrow Potat. Celerede 57.ft seen. IM ft high. 206 ft long Schist. guartatte 400-ft rock cover (1980) greafte pertege Ben. Orltish 67.ft seen.144 ft high. 890 ft long Sandstone. shale Peer rock condittent centrote reef arch Columble proefdeds 200-ft rock cover (1970)

Churchill Falls. SI ft seen.146 ft high.1000 ft long Greette,greafte/ Largest h lettrtC project in Western Lehredor. Cenede snetes toerid ( pas): 100-ft sock covers 2.5 by 100yd3 encovetten(1971)

Sorce-8tenese Italy 95-ft spen. 92 ft hfgh. 433 ft long Waldeck 11. naast Gereesqr lle-ft seen Pumped storage recility Its1 den. Norway 33-ft spen. 85 ft high. 98 ft long Gaetts neck cover 100 to 200 ft: Itaed with reinforced concrete and patated (1960)s 20-8tf(t) be11 tag h heavy-meter reacter Y Agesta. Sueden 54-ft spen.130 ft high 175 ft long Gneiss /greafte Rock cover 56 ft: Ifned with concrete and steel (1964)3 60-ftf(t) belltag heavy-teter reactor 50th. Cheet. france 61.ft spen. IM ft high.140 ft long Chelt/ shale Sreuttags 1/13 to. steel lletagt 275-8tf(e) Ptst Lucens. Suitseriend $9-ft diameter 95 ft high Sedtsentory melesse fue layers of concrete. aluminum fetl and httasmen seals 3.3-pal (e) ges-cooled heavy-wter reacters partial meltdema 1969 decommissteneds cavera desttaed for redussee disposal References leuclear Safety 15(5) fette 1.

Peteattel ground ester problems are teentified la items 3. 5, 7. and 13 from the IIncleer Safety 16(4) article pgs. 4M-435 (July-August 1975).

interrogotory 56 Compare the criteria used in your conclusion that unresolved safety problems associated

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with undergrounding partially worront rejecting that alternative but other unresolved safety problems associated with the CRBR obove or underground do not partially worront totally rejecting the CRBR. In your answer, explain how you compare the status of resolution of the unresolved safety problems.

Response

The Applicants have stated that unresolved technical problems (ground water, flooding, structural, sealing of penetrations, etc.) represented one of the considerations involved in rejecting the underground siting concept. The underground siting concept would involve demonstration of this concept along with the existing Project objectives but without on opparent offsetting odvantage for the concept. With respect to the Applicants' position on unresolved safety questions for CRBRP, see the response to interrogatory 58.

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Interrogatory 57 in your November 18,1976, submittal, you state at the end of Section 2.3.2:

In addition, with no engineering design existing for on underground nuclear picnt in the U.S., and no application having been filed to locate a plant at on underground site, the additional burden of demonstrating the concept of underground siting along with the LMFBR Demonstration Plant existing objectives would be unreasonable and would severely impoct and jeopardize the LMFBR Demonstration Program.

To what extent has your decision on possible changes in the CRBR design been influenced by this consideration?

Response

The impoet and jeopardizing of LMFBR Program and Project objectives was one of the factors which led to o judgment to eliminate the concept of underground siting as discussed previously.

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fl Interrogatory 58 Is it your position that in deciding whether on unresolved safety proble.m related to the CRBR should be resolved prior to construction, the possible delay in beginning construction is a consideration? If so, to which problems does this relate?

Response

it is the Applicants' position that while recognizing that some construction milestones may be dependent upon the resolution of safety issues, construction may begin if there is reasonoble assurance that all unresolved safety questions will be satisfactorily resolved prior to completion of construction. The Applicants believe that there are no unresolved safety problems which would preclude beginning of construction.

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interroootory 59 With respect to reliability, explain the basis for your belief that the CRBR ovoilobility is a relevant consideration rather than copocity factor?

Response

The CRBRP Project is using the definition for availability as the rotio of time that the plant is capable of producing power in a given period to the total ilme in that period.

This measure of performance in a utility environment will be estimated primarily from meon-time-between-failures (MTBPs) and meon-time-to-repair (MTTR) values obtained from reliability and maintainability analyses and testing, cnd verified during the five year plant demonstration.

The verification dato obtained for plant ovallobility will have more meaning for the utilities, since a great deal more data on personnel, logistics, support functions, and performance, and equipment histories and records would be required to establish a credible copocity foctor, in addition, since the Project is of a demonstration nature, complete shutdowns con be expected to occur more frequently during the demonstration period, rather than operation at reduced copocity. Utilities con ossess the impact of these shutdowns (i.e., for modification, procedure deficiencies, etc.) to establish expected operational chorocteri; tics and estimated copocity factor.

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Interrogatory 60 Explain your basis for believing that the CRBR will usefully demonstrate plant reliability in light of the following considerations:

(a) Low copocity foetors for new generation reactors; (b) Unrealistic reliability results from any reoctor which is os closely watched as the CRBR both during construction and operation.

Response

The reliability program is a preventative tool which will reduce equipment failure and plant down time during the demonstration and operating plant period. This program is providing on understanding of failure chorocteristics ed maintenance requirements which was not known during the design and development of currently operating LWR's or fossil plants. In view of this odded visability, o more realistic assessment con be mode of the potential plant capabilitie even though the Project is of a demonstration nature os pointed out in the response to 59 obove.

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concil l

• 500 W. EagMh Screet Sete 110 Wncouver.WA 98660 (206) 894 8593 (503) 241 3183 February 16, 1982 Mr. William Rolf Project Management Corporation Clinch River Breeder Reactor Project P.O. Box U '

Oak Ridge, Tennessee 37830 -

RE: Use of Hanford, Washington Site for LMPBR Demonstration Plant

Dear Mr. Rolf:

This letter will confirm that Pacific Northwest consumer owned utilities are not prepared to assume the project manager or owner role for a LMFBR demonstration plant at Hanford. Today, therefore, the Public Power Council Executive Committee agreed that the Clinch River site is the most appropriate location.

Very truly yours .

g.tv (d Robert M. Greening, J .

Manager p

RMGresn 4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of U. S. DEPARTMENT OF ENERGY DOCKET NO. 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, CRBRP Project, and that he is duly authorized to answer Interrogatories 1-60 in the Twelfth Set of Interrogatories.

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

um

. nas Sigtur 7 SUBSCRIBED and SWORN to before me this_/9 day of ,

1982

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' ~~ /AL N6 tar u511c My Commission expires , 19 .

My Commission Expirn April 28. 1984 l

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION In the Matter of U. S. DEPARTMENT OF ENERGY DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY AFFIDAVIT OF LAWRENCE J. KRIPPS Lawrence J. Kripps, being duly sworn, deposes and says as follows:

1. That he is employed as a Safety and Environmental Engineer, of Energy Incorporated, and that he is duly authorized to answer interrogatories numbered 1-60 in the Twelfth Set.

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

mMw l ignature ///

/'

SUBSCRIBED and SWORN to before me this /M day of I) ,1982.

f Afb M51-Not Public My Commissien D;.a April 23.1984

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O

)

In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMINT COP.PORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

CERTIFICATE OF SERVICE Service has beer. effected on this date by personal delivery or first-class mail to the following:

• 1krshall 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 Cc.331ssion Washington, D. C. 20545 ,

• Daniel Swanson, Esquite

• Stuart Treby, Esquite Office of Executive Legal DiTector 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 i U. S. Nuclear Regulatory Commiraion Washington, D. C. 20545 (3 cepies)

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 l

l Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire l 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)

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1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006 l

4 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.

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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 W -

Geor Attorney  % for

. EBgai' [

Project Management Corporation DATED: April 20, 1982

• / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.

• • / Denotes hand delivery to indicated address.

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