ML20054H567

Response to Licensee 820604 Request for Admissions & Interrogatories

ML20054H567
Person / Time
Site:	Clinch River
Issue date:	06/18/1982
From:	Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	CONSOLIDATED EDISON CO. OF NEW YORK, INC., JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
Shared Package
ML20054H568	List: ML20054H567 ML20054H576
References
NUDOCS 8206240209
Download: ML20054H567 (30)

Text

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June 18, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Marsnall E. Mille r, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

)

In the Matter of )

)

) Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

I-RESPONSE OF INTERVENORS , NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB, TO APPLICANTS ' REQUEST FOR ADMISSIONS AND INTERROGATORIES DATED JUNE 4, 1982 Pursuant to 10 CFR S 2.7406, and in accordance with the Board's Prehearing Conference Order (Schedule) of February 11, 1982, Intervenors, Natural Resources Defense Council, I nc . a nd the Sierra Club, hereby respond to Applicants' Request for Admissions and Interrogatories, dated June 4, 1982.

8206240209 820618 PDR ADOCK 05000537 C (h ~)

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2-A. REQUEST FOR ADMISSIONS

1. Tne only portion of the PSAR which Intervenors believe constitutes a concession tnat the containment design is insufficient if conservative estimates are used in CDA analyses is the " existence of the Parallel design (since withdrawn) . "

See Intervenors' Update to Applicants' First Set of Interrogatories at 8.

RESPONSE

Intervenors admit this statement based upon our review to date. Intervenors note that it is the information in the Parallel design, not just the existence of the Paraliel design, tha t Intervenors believe constitutes a concession that the confinement design is insuf ficient if conservative estimates are used in the CDA analysis. There are many assumptions in the PS AR and referenced documents that Intervenors believe a re not conservative or not suf ficiently conservative. While we believe the containment design would be demonstrated to be insufficient if these more conservative assumptions were made, we a re not aware that the Applicants would concede this.

2. Intervenors can identify no specific accident initiators, sequences or events wnich snould be included within the spectrum of design basis accidents.

H ES PONSE Intervenors deny this statement. Applicants and Staff nave identified initiators which Intervenors believe should be witnin the design basis. CRBHP-1 and CRBRP-3 also identify initiators tnat should be witnin the design basis, such as unprotected LOF and TOP events. We would also include station blackout, sabotage, and earthquakes as major contributors to tne overall probability of CDA initiation. Intervenors a re presently reviewing response s to discovery, PSAR, and ACR9 transcripts to complete their analysis. Intervenors cannot be more specific in part because the Board has disallowed d i scove ry on CRBRP-1.

3. Intervenors cannot identify, and have no knowledge of the specific meteorological parameters for CRBRP, including wind speed, i nve rsion conditions, frequency and other pertinent meteorological parameters, which Intervenors consider to be suf ficiently unf avorable that an alternative site should be selected.

RES PONSE Intervenors deny this statement. The meteorological carameters specified by Applicants in the ER and by the Staf f in the FES a re suf ficiently unf avorable.

4. Intervenors cannot identify and have no knowledge of the specific value of each particular meteorological parameter f o r CRB RP, including wind speed, inversion conditions, frequency, and otner pertinent meteorological parameters which Intervenors consider to be minimally acceptable for CRBRP.

RESPON3E Intervenors cannot admit or deny this statement. Tnis statement implies tha t Intervenors view their Contention 5 as requiring a minimally acceptable level for each meteorological parameter. Intervenors believe that the doses to individuals at each site should be compared, not individual meteorological parameters.

5. Tnere is an extensive base of 'LMFBR design, construction and operating experience which has been developed over the last 28 years, both in the U.S. and in otner countries, which is available for use in the safety evaluation of CRBRP technology.

RES PONS E Intervenors deny this statement. Intervenors do not believe the LMFBR design, construction and operating experience is extensive, particularly in tne U.S. Intervenors deny that all foreign LMFDR experience is available for use in the safety evaluation of CRBRP technology, since mucn of it is proprietary.

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6. It can be safely concluded enat HCDAs can be excluded as design basis events considering this axtensive LMFBR technological base in conjunction with the preventive design features included in the CRBRP. .

RES PONSE Intervenors deny this statement. Intervenors do not believe tne LMFBR technological base is extensive and do not believe the CRBRP preventive design features are suf ficient to exclude CD As as design basis events.

7. ANL-RDP-23; ANL Monthly Prog ress Reports, December 1973 ; SAND 76-0273 ; NUREG-766501, July 1976; and the Applicants' computed results provide evidence that f,uel axial expansion occurs even during power transients.

RESPONSE

Intervenors cannot admit or deny this statement.

Intervenors have not reviewed the ANL and Sandia progress reports.

NRC Publications has no record of NUREG-766501. In any case, even if axial fuel expansion is discussed, Intervenors believe these documents would provide evidence only that fuel axial expansion may occur during some power transients. See answer to Request f or Admission # 9 below.

8. Tnere are relatively slow power changes occurring during the initial period of an LOF event.

RES PONSE Intervenors admit this statement if by " initial period" Applicants mean "first few seconds," and if the LOF event is unprotected (failure to scram).

9. During an LOF event, tne early fuel axial expansion is a prompt negative feedback that can alter the energetics of the event as documented in Section 7. 2.3 in CRBRP-GEPR-00523 a nd Sec t ion 7. 2. 2. 3 i n CRB RP-GEFR-0 010 3.

RES PO NS E . - - _ _ ___.

Intervenors deny this statement. Ea,rly f uel axial expansion is net documented in Section 7.2.3 of CRBRP-GEFR-00523. S ee a lso Section 3.1. 4.1.1 of NUREG-012 2, which states that "[tlhe axial expansion process has not been studied tnoroughly enough to justify its f ull utilization in accident analysis at the present time."

10. Intervenors have no evidence that axial f uel expansion will not occur on the time scales required to alter the energetics of an LOF event.

RES PONSE Intervenors admit this statement a s pnrased. Intervenors, however, do not believe that Applicants should take credit for l axial fuel exoansion in their accident analysis since Applicants and Staf f cannot predict witn high confidence that it will significantly af fect the course of events. See NUREG-0122.

11. In terms of the pressure pulse applied to the head under an HCDA load, the upper internals structure would atteneate the loads.

RES PONSE Intervenors admit this statement wit,hout admitting that the degree of attenuation would be significant or that Applicants snould take credit for attenuation in their accident analyses.

12. In light of Admission 11, neglecting the upper internal structure provides a conservative representation of the loads on the reactor closure head.

RESPONSE

Intervenors admit this statement to the extent that neglecting the upper internal structure may make calculations of loads smaller than otherwise, but do not admit that Applicants' accident analyses are conservative or that neglecting the upper internal structure would provide a significant conservatism.

13. The snea r ring is capable of retaining the reactor ve ssel head f or tne 66l megajoule HCDA case with a suostantial margin to f ailu re.

RESPONSE

Intervenors deny this statement. See letter from Buni to Boyd, dated Aug. 16, 1976; letter f rom Tnomas P. Spels to Dr.

Dade W. Moeller, dated Dec. 7, 1976; and letter from Paul S.

Check to John R. Longenecker, dated June 9, 1982.

14. All changes in reactor vessel and core design relevant to accident modeling have been included in Applicants' accident modeling.

RES PONSE ,

Inte rvenors cannot admit or deny t'his statement.

Intervenors do not understand what Applicants mean by " accident modeling." Fo r example, CRBRP-1 and CRBRP-3 a re based upon analyses of the homogenous core.

15. Tne only technical bases for Intervenors' contention that HCDAs are credible events are those listed in Intervenors' response to Inter rogatory 3 (f) of Applicants' Fourtn Set of Inte r roga to rie s.

RESPONSE

Intervenors deny that the technical bases referred to are the only technical basis for Intervenors' contention that CDAs i

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_9 are credible. With the exception of sabotage, whien snould 4

also be included, tney state the broad outlines of Intervenors' case, which will be fleshed out with further technical i

arguments and reasoning. Intervenors also note that their contention >fers to CDAs, not HCDAs, since Intervenors are i

re fer ring to credible accidents as well as nypothetical ones,

16. Intervenors have not performed any analysis which substantiates the claim that Applicants have not adequa te ly considered in the radiological source term analysis the environmental conditions in tne reactor containment ouilding c reated by the release of substantial quantities of sodium.

RESPO NSE Intervenors deny this statement. Intervenors nave analyzed the PSAR and many technical documents involved in this case.

Intervenors do not believe that 1,000 pounds of sodium is an adequate design basis assumption for CDAs.

17. Intervenors cannot identify and have no knowledge of any environmental conditions in the reactor containment building created by the release of substantial quantities of sodium which were not adequately considered in the radiological source term analysis.

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RESPONSE

Intervenors deny this statement. Tnose environmental conditions include sodium spray and pool fires, combined with sodium-concrete interactions. See FES, p. 7-7. Intervenors do not believe Applicants will suf ficiently protect against these conditions unless CDAs a re included within the design basis e n ve lope . ,

18. Intervenors have no f actual basis for the claim that Applicants have not adequately considered in the radiological source term analysis the environmental conditions in the reactor containment building created by the release of substantial quantities of sodium.

RES PONSE Intervenors deny this statement. In te rveno rs ' factual basis for this claim is tnat Applicants have not considered these environmental conditions in their site suitability source term accident analysis at all.

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19. Intervenors agree with the leak rate assumptions appea ring on III-19 of the SSR for the assumed core f raction released to toe containment.

RES PONSE Intervenors have not performed an analysis which would lead them to accept or challenge the leak rate assumptions for tne

assumed source term utilized in SSR Table III-19. As Intervenors nave previously stated, nowever, we believe that the source term should be larger and include environmental conditions associated with the release of substantial quantities of sodium. These sodium quantities would affect the leak rate due to overpressurization and could also reduce tne filter efficiencies.

20. Intervenors have no technical basis for concluding that " filters will [not] perform at the stated efficiencies in an environment where large quantities of sodium have been released and sodium and nydrogen combustion have taken place."

Intervenors' Response to Interrogatory 3,(j) of Applicants' Fourth Set of Interrogatories.

RESPON3E Intervenors deny this statement. The accidental fires at the Rocky Plats Plant in 1957 and 1969 resulted in filter efficiency failures (see FES - Rocky Flats Plant Site, DOE /EIS-0064, Vo l . 1 o f 3, Ap r il 19 8 0, p. 3-5 3) . Intervenors recall seeing otner documentation on tnis issue out have not yet been able to retrieve such documents.

21. Intervenors have no technical basis for concluding tha t venting is an unacceptable method of accommodating HCDAs.

RES PONS E i

Intervenors deny this statement. Intervenors believe the l l l l unacceptability of venting is one of the lessons learned from the TMI-2 accident, including the controversy over venting of Kr-8 5 f rom the TMI-2 containment and tne Commission's proposed

, rule on interim nydrogen control (45 Fed. Reg. 62281, Dec. 23, '

19 81) ( Cf . , Kendall, et a l. , " Statement of Union of Concerned Scientists on the Tnree Mile Island Krypton Gas Venting," May 14, 1980).

22. Intervenors' sole basis for concluding. that Applicants have not adequately analyzed all accidents associated with_ core __ ___ _

meltthrough following loss of core geome,try and sodium-concrete interactions is that Applicants h$ve not treated HCDAs as DBAs.

RESPONSE

Intervenors deny this statement. Intervenors do not believe the behavior of sodium concrete interactions, coolant boiling, sodium (e.g., spray) fires, and aerosol behavior a re suf ficiently well understood (cf., Transcript of ACRS Meeting ,

May 25, 1982); Breitung, et. al., " Foreign Attaches Quarterly Prog res s Report , " May 1- Aug . 31, 1981. Intervenors do not believe current models and understanding a re suf ficient to Interveno'rs d inot-

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l confidently predict events in these areas.

believe CRBR should be built with limestone concrete from the Clinch River a rea.

23. Intervenors cannot identify and have no knowledge of any population characteristics of the CRBR site wnich Intervenors believe are sufficiently unfavorable that an

, alternative site should be selected.

RES PONSE Intervenors deny tnis statement. Intervenors a re aware from discussions in the ER and FES that other sites (e.g.,

, Hanford, INEL, and NTS) have more favorable population cnaracteristics. See generally Intervenors' Answers to Inter rogatories related to NRDC Contention 5 (formerly NRDC 6) of NRC Staff First Round of Discovery to NRDC, et. al.

24. The only alternative sites whic,b Intervenors believe have population densities which are more favorable than the 4

population density of the CRBR a re Hanford Reservation and Idaho National Engineering Laboratory.-

RESPONSE

Intervenors deny this statement. Amchitka and other sites also have more favorable population densities. It is not Intervenors' responsibility to conduct an adequate alternative site review. We attempted to list as alternatives DOE sites we wished to have considered and wnich we believe represent preferred sites to the CRBR site.

25. Intervenors nave not analyzed and have no knowledge of tne population densities of Hanford Reservation or Idaho National Engineering Laboratory.

RESPONSE

Intervenors deny this statement. See FES, p. 9-11. See also Final Environmental Statement, Waste Management Operations, Hanford Reservation, Ricnland, Washington, Sec.

II.3.2 (Dec. 1975); Final Environmental Impact Statement, Waste Management Operations, Idaho National Engineering La boratory, Idaho, Sec. II.C.2 (Sept. 1977). l l

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26. Tne only "new knowledge" referred to in Contention 11 (Old 8) is contained ICRP26, ICRP3 0, 40 ,CFR Section 190.10 and EPA 520/4-77-016.

RES PONSE Intervenors deny this statement. These were cited as examples only. Other new knowledge can be expected to be identified as we continue to prepare our case.

l 27. Tne only "recently discovered omissions" referred to in Contention 8 (Old L4) a re the analyses of Nickel-59 and Niobium-94.

RESPONSE

Intervenors deny tnis statement. These a re the only "recently discovered omissions" currently known to tne Intervenors. There may be others, nowever.

28. The only neutron activation products referred to in Contention 8 (Old l4) are Nickel-59 and Niobium-94.

RES PONSE Intervenors deny this statement. We refer to "all neutron activation products" in Contention 8d, not just Nickel-59 and Niobium-94.

29. Intervenors have not analyzed and nave no knowledge of the environmental conditions which they believe should be considered in the radiological source term analysis.

RES PONSE Intervenors deny this statement. Intervenors are generally aware of the environmental conditions that would occur following an energetic CDA that breached the reactor vessel (e.g., through head seal leakage) , or following a whole core fuel melt CDA that would melt through the reactor vessel.

These conditions are generally described in documents such as CRBRP-L and CRBRP-3 and in testimony before the ACRS. (See Transcript of ACRS Subcommittee on CRBR, May 24 - 25, 1982.)

30. Intervenors have no casis for the conclusion that any relevant or necessary environmental conditions were not considered in the radiological source terin analysis.

RES PONSE Intervenors deny this statement. See NUREG-0786, Site Suitability Report in the Matter of Clinch River Breeder Reactor Plant (Revision to March 4, 1977 Report).

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31. Intervenors have not analyzed and have no knowledge of the ma <imum crediole sodium release following a HCDA.

RESPONSE

Intervenors deny this statement. The maximum credible sodium release is approximately 1-1.2 million pounds of sodium.

(See generally CRBRP-1 and CRBRP-3) .

32. Intervenors' sole objection to Applicants' and Staff's accident analysis is tnat HCDAs are not included as DBAs.

RES PONSE Intervenors deny this statement. Tne contentions speak for themselves.

33. Intervenors agree with Applicants' analysis of accidents which are included within the design base.

RESPONSE

Intervenors deny tnis statement. Intervenors believe that some of the accidents analyzed by Applicants as within the design basis could lead to CDAs, e.g., LOF initiators, loss of AC power, and earthquakes. Intervenors of course do not agree witn Applicants' definition of the DBA envelope.

34. Intervenors have not developed and cannot identify the specific acceptance criteria which Intervenors contend must be utilized to assure that core meltthrough accidents are adequately analyzed.

i RESPONSE Intervenors deny this statement. One criterion would be to treat CDAs as design basis accidents. For example, Applicants should modify General Design Criterion 41 to include "CDAs involving full core melt with reactor vessel melthrough and CDAs involving energetics in excess of the reactor vessel design basis" as examples of the " postulated accidents" referred to on line 8 of Criterion 41.

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35. The only meteorological parameters or factors which mu9t be utilized in evaluating site meteorology a re wind speed and inversion conditions.

RESPONSE

Intervenors deny this statement. One must evaluate all the parameters necessary to conservatively predict the movement of radionuclides from tne reactor to the points on tne site boundary and beyond. For example, wind and particle motion must ce treated as vector rather than scalar quantities.

36. Intervenors cannot identify and have no knowledge of any sites with more favorable wind speed and inversion conditions than the CRBR site.

RESPONSE

Intervenors deny tnis statement. Staff nas indicated that the atmospheric dispersion of the three alternative sites

(Hanford, Savannan River, and INEL) are superior to that at the Citnch River site (FES p. 9-11) . A reasonable inference from this statement i s that the wind speed and inversion conditions at sucn sites are superior to the Clincn River site.

37. Intervenors have not analyzed and cannot identify any meteorological disadvantages of the CRBR site.

RESPONSE

Intervenors deny tnis statement. See answer to Request for Admission 36.

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8. INTERROGATORIES

1. For each statement in the foregoing Request for Admissions which you deny, provide the following information:

the specific portion of tne statement which is not admitted and.

the documents (if any) and witnesses (if any) which provide the basis for your disagreement with the statement.

RES PONSE The answer to this Interrogatory is provided under each Request for Admission above tnat Intervenors deny.

2. For ea_ch_stateme_nt _in__tne foregoing Request for Admissions which you can neither admit nor deny, provide the following information:

a. The portion of the statement which is not admitted, and the basis for your inability to either admit or deny the statement.

6. If the basis is tnat you have not completed your analysis, please describe in detail the nature of the analysis being undertaken, the person (s) performing the analysis, the preliminary results of the analysis, if any, and the date wnen you expect to complete your

~ analysis.-

RES PONSE Tne answer to this Interrogatory is provided under eacn Request for Admission above that Intervenors can neither admit nor deny.

3. If not provided in response to Interrogatory 2.c.

above, please provide tne following information with regard to the " analysis" referred to by NRDC in response to Interrogatory 3(c) of Applicants' Fourth Set of Interrogatories to Intervenors: a detailed descripticn of the nature of the analysis, any preliminary results of the analysis, the I

pe rso n ( s) performing the analysis, the date wnan Intervenors expect the analysis to be comrileted, and if the analysis is complete, provide the results of the analysis including all assumptions made in performing the analysis, all data or information used in performing the analysis and identify all documents relating to or referring to such analysis.

RES PONSE The nature of Intervenors' analysis is a review of the PSAR and other documents forming a part of this case, to the extent they are not outside the limits of discovery according to tne l Boa rd 's Orde r. The preliminary results of our analysis have been set out in Intervenors' response to Interrogatory 3(c) of '

Applicants' Fourth Set of Interrogatories to Intervenors. Dr.

Cochran is performing the analysis. Intervenors are attempting to complete their analysis in accordance with the Board's Order of February 11, 1982.

4. In response to Interrogatory 3 (4) of Applicants' Fourth Set of Interrogatories, Interveaors make the following statement:

Intervenors believe such bounding releases would lead to very different assumptions regarding the environmental conditions in the reactor building, primarily due to the assumptions that substantially more than 1000 lbs. of sodium would be released.

Witn regard to this statement, please provide the following information:

a. a detailed des,cription of the "very dif ferent assumptions" referred to in the statement, and with regard to each such assumption, state the technical and/or factual basis for the assumption, and identify all documents which Intervenors'believe support each assumption.

b. Describe in detail the basis for the " assumption that substantially more tnan 1000 lbs. of sodium would be released", and identify all studies, analyses, reports or any documents which support the statement.

RES PONSE 4.a. Applicants' and Staff's site suitability source term analysis does not consider the pressure, temperature, and aerosol conditions in the containment that would be associated with releases of substantial quantities of sodium f rom tne reactor vessel as could occur in CDAs. These conditions a re generally, altnough not necessarily accurately, completely, or conservatively, described in CRBRP-1 and CRBRP-3.

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4. b. CRBRP-1 a nd CRBRP-3, Vo l . 2, contain analyses assuming a much greater release of sodium tnan 1000 pounds.

See Transcript of Deposition of Applicants, June 16, 1982.

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5. In response to Interrogatory 3(n) of Applicants' Fourth Set of Inter rogatories, Intervenors make the following statement:

The principal issue is the percentage of fission product and fuel (other than noble gases and halogens) that should be considered as part of the source term.

Witn regard to this statement, please provide the following information:

a. State the percentage of fission product and fuel (other than noble gases and halbgens) that Intervenors believe should be considered as part of the source term.

b. Describe in detail the technical and/or f actual basis for the percentage including any analysis undertaken by Intervenors to a rrive at this percentage and the pe rso n ( s) who performed this analysis.

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c. Identify all studies, analyses or reports which support the percentage.

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RES PONSE 5.a. Approximately 20% of the fuel and nonvolatile fission products.

5. b. A review of CRBRP-L and CRBRP-3 provides some of the basis for this percentage. EBR-II Hazards Summary Report

(

provides an even greater percentage of plutonium (i.e., 50%).

Intervenors believe 20% of fuel and nonvolatile fission products provides a suf ficient margin of conservatism. Dr.

Cochran performed the analyses.

5.c. See answer to 5.b. above.

6. In response to Interrogatory 3(j) of Applicants' Fourth Set of Interrogatories, Intervenors make,the following statement:

To date Intervenors have not performed any analyses that would lead them to challenge the leak rate assumptions appearing on p.

III-19 of the SSR for the assumed core f raction released to containment.

With rega rd to this statement, please provide the following information:

a. State whetner Intervenors intend to challenge the leak rate assumptions referred to in the statement and if 1

l so, provide the oasis for tne challenge to the leak rate assumptions including any analyses, reports, or studies supporting Intervenors' challenge.

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RES PONSE 6.a. Intervenors do intend to challenge these assumptions. The primary basis for this cnallenge is that these assumptions a re not valid under environmental conditions associated with the release of substantial quantities of sodium. Supporting documents include CRBRP-1 and CRBRP-3.

7. In response to Interrogatory 3(j) of Applicants' Four+.n Set of Interrogatories, Intervenors make tne following statement:

We question whether Staf f/ Applicants have demonstrated that the filters will perform at the stated ef ficiencies in an environment ,where la rge quantities of sodium have been released and sodium and nydrogen combustion have taken place. Intervenors believe that venting is an unacceptacle method of accommodating severe CDAs.

Witn regard to this statement, please provide the following information:

a. Describe in detail the technical and/or f actual bases which lead Intervenors to question whether "the filters will perform at the stated efficiencies ..."

including a description of any analysis undertaken by Intervenors which leads you to question the efficiency

of tne filters and the identity of the person (s) who performed such an analysis,

b. Identify any studies, reports, or analyses which lead Intervenors to question the efficiency of the filters.

c. Describe in detail the technical and/or factual basis for Intervenors' belief "that venting is an unacceptable method of accommodating severe CDAs" including a description of any analysis undertaken by Intervenors which supports your belief that " ve nt i ng is an unacceptable method of accommodating severe CDAs," and the identity of the person (s) performing such analysis. . _ _ _ _ _ _ _ _ _ .

d. Identify all analyses, studies,,or reports which sup po r t Intervenors' belief that " venting is an unacceptable method of accommodating severe CDAs."

e. Define the phrase " severe CDAs."

RES PONSE 7.a. Tecnnical and/or f actual bases f or this statement include tne f act that Applicants nave provided no evidence to support their claim that the filters will perform at the stated ef ficiencies given a core disruptive accident.

7. b. See Transcript of Meeting, ACRS Subcommittee on CR8R, Ma y 2 5, 19 8 2, p . 452. Intervenors also believe that

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Applicants' proposed venting of the containment is a concession that the filters will not perform at the stated efficiencies.

i 7. c . See response to Request for Admission # 21.

7.d. See response to Request f or Admission # 21.

7.e. " Severe CDAs" in the context of our response to Interrogatory 3(q) means CDAs involving the release of substantial quantities of sodium that would in turn result in pressure, temperature, or other conditions which would exceed the design capability of the containment in the absence of i

venting.

8. In response to Interrogatory 4(c) of Applicants' Fourth Set of Inter rogatories, Intervenors state that "our analysis is incomplete. ..." With regard to this statement, please provide the following information. ,

a. Describe in detail the nature of the analysis you are conducting, including all assumptions made in performing the analysis, all data or information used, any preliminary results of tne analysis, the person (s) performing the analysis, and the date wnen Intervenors expect the analysis to be completed.

b. If the analysis is complete, provide the results of the analysis and identify any documents which describe tne analysis or the final results.

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{, RES PONSE-8.a. Intervences' analysis consisted of reviewing CRBRP-1 and other probabilistic risk assessments performed by Applicants and Staff. This review and associated discovery has been deferred until the CP stage by the Board's Order of April 1 22, 1982. Our preliminary results a re that a CDA snould be

witnin the design basis spectrum.

8.6. Not applicable.

9. In lignt of Intervenors' response to Interrogatory 3-3.c. of NRC's 1st Round of Discovery in which Intervenors state that they have not yet developed scientific acceptance criteria to be used in judging the adequ,acy of core meltthrough accident analyses, explain the basis f'or Intervenors' Contention 3c which states that accidents associated with core meltthrough f ollowing loss of core geometry and sodium-concrete interactions nave not been adequately analyzed.

RES PONSE

9. Intervenors have developed such criteria in a preliminary manner. See response to Request for Admission #34.

10. In response to Interrogatory 6(a) of Applicants' Fourth Set of Inter rogatories, Intervenors make the following statement:

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On the basis of additional analysis, Intervenors would modify the conclusion on p.

L3 of that document i n the following respects.

With regard to this statement, please provide the following i nformation:

a. De sc ribe i n detail the " additional analysis" referred to in the statement, including a description of any assumptions made, any data or information used, identify any documents relied upon and identify the person (s) who performed the analysis.

RES PONSE 10.a. Tne additional analysis includes a review of the documents cited in -'sponse to Interrogatory 6(a) of Applicants' Fourth Set of Interrogatorie,s to Intervenors. Dr.

Cocnran performed tne analysis. kntervenorshavealsoanalyzed

- tne comments of the NRC Staff and DOE.

11. In response to Inter rogatory 6(a) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

Regarding the ICRP Publication 26 approach, Intervenors cur rently believe the weighting f actors and organ dose li.mts (" caps" to prevent non-stockastic ef fects) recommended by EPA should be used rather than those recommended by ICRP 26.

With regard to this statement, please provide the following information:

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a. Describe in detail all factors leading Intervenors to believe that the EPA weighting factors and organ dose limits snould be used rather than those recommended by ICRP 26. The answer to tnis interrogatory should identify all reports, studies, or analyses which support Intervenors' oelief,

b. Identify all documents relating to or referring to the weignting f actor or organ dose limits recommended by EPA and those recommended by ICRP 26.

RES PONS E ll.a. The Environmental Protection Agency is responsible for Federal radiation protection guidance, not the ICRP.

Intervenors' preliminary view is that EP,A's weighting f actors represent more conservative assumptions more in line with the NRC's reactor safety philocophy. EPA's o rgan dose " caps" to prevent non-stochastic ef f ects are clearly more conservative, ll. b. These documents include Letter from Nunzio J.

Palladino to Ms. Ann McGill Gor such, dated July 2 4, 1981, (enclosing NRC comments on the 'croposed " Federal Radiation Protection Guidance for Occupationa l Exposu re" (46 Fed. Reg. 7836)); Department of Energy Testimony at EPA Public Hearings, April 20-23, 1981, presented by Davi'd E. Patterson; Lette r f rom Stephen H. Greenleigh, DOE, to Director, Criteria and Standards Divis io n ( ANR-49 0p, EPA, dated July 10, 1981,(re: Docket No.

A-7 9-4 6) .

%o o

Respectfully submitted,

/:dhe A-6ttitS--

Ba'r ba r a A. Finamore S. Jacob Scherr 1725 I Street, NW, Suite 600 Washington, D.C. 20006 (202)223-8210

1. 1r k kla , Bse)

Ellen fM Weiss (

Harmon & Weiss 1725 I Street, N.W.

Washington, D.C. 20006 (202)833-9070 Attorneys for Intervenors Natural Resources Defense Council and. Sierra' Club Dated: June 18, L982 ,

,