ML20054M763

Twenty-sixth Set of Interrogatories.Certificate of Svc Encl

ML20054M763
Person / Time
Site:	Clinch River
Issue date:	07/13/1982
From:	Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8207140378
Download: ML20054M763 (33)

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Ju ly 13, 1982 cc a:.13 P4 58 UNITED STATES OF AMERICA tr, c- n~'

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NUCLEAR REGULATORY COMMISSION .  : ~

ATOMIC SAFETY AND LICENSING BOARD i Before Administrative Judges:

Marshall E. Miller, 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) )

)

NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB TWENTY-SIXTH-SET OF INTERROGATORIES TO STAFF Pursuant to 10 CFR b 2.740b, and in accordance with the Board's Prehearing Conference Order of February ll, 1982, Intervenors, Natural Resou rces Defense Council, Inc. and the Sierra Club, submit the following interrogatories relateo to the Site Suitability Report in the Matter of Clinch River Breeder Reactor Plant (Revision to March 4, 1977 Report),

NUREG-0786, June, 1982. Intervenors request that the attached interrogatories be answered fully, in writing ano under oath, 8207140378 820713

$DRADOCK 05000537 PDR C]

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2 by one or more orficers or employees of Staf f who has personal knowledge thereot or is the closest to having personal knowledge thereof. If the interrogatories are answered by more than one person, whether or not he or she verified the answers, and whether or not he or she is an officer or employee of Staff, such person's name and title should be set forth together with an identification of which interrogatories he or she is responsible for.

Each answer to an interrogatory shall be preceded by a copy of the particular question to which the answer is responding.

Each q uestion is instructed to be answered in six parts, as follows.

Answer to Question  :

(a) Provide the direct answer to the question.

(b) Identify all documents and studies, and the particular parts thereof, relied upon by Staf f, now or in the past, which serve as the basis for the answer. In lieu thereof, at Staft's option, a copy of such document ano stuoy may be attached to the answer.

(c) Identif y principal documents and studies, anc the particular parts thereot, specitically examined but not cited in (b). In lieu thereof, at Staff's option, a copy of each sucn document and stucy may be attached to the answer.

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(d) Identify by name, title and affiliation the primary Staf f employee (s) or consultant (s) who provided the answer to the question.

(e) Explain whether Staff is presently engaged in or intends to engage in any further, ongoing research program which may aftect Staff's answer. This answer need be provided only in cases where Staff intends to rely upon ongoing research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR. Failure to provide such an answer means that Staff does not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.

(f) Identify the expert (s) it any, which Statt intends to have testify on the subject matter questioned, and state the q ualitications of each such expert. This answer may be provided for each separate question or for a group of related guestions. This answer need not be provided until Staf f has in f act identified the e xpe rt ( s) in q uestion or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.

As used herein, " documents" include, but are not limited to papers, photographs, criteria, standards ot review, recorcings, memoranda, books, records, writings, letters, telegrams,

4' mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoftice, intra-agency or interagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, stuaies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printou t sheets, computer data, telecopier transmissions, directives, proposals, and all draf ts, revisions, and aiffering versions (whether f ormal or inf orma l) of any of the foregoing, and also all copies ot any of the foregoing which dif fer in any way (including hanawritten notations or other written or printed matter or any nature) from the original.

5 INTERROGATORIES These interrogatories all relate to the June 1982 Site Suitability Report in the Matter of Clinch River Breeder Plant (Revision to March 4, 1977 Report), NUREG-0786 (the "1982 SSR"). The specific page number (s) referred to are indicatec in parentheses at the beginning of each interrogatory.

I. General Questions

1. For each principal Staff contributor responsible for.

reviewing any portion of the 1977 SSR, indicate a) which portion of the SSR was reviewed by such person; b) who was responsible for making each revision to the 1977 SSR, as indicated by a vertical bar in the right hand margin of the pages of the 19 82 SSR.

2) Please update every Staf t response to Intervenors' interrogatories, requests for admission, requests for production of documents, and deposition questions to reflect additional Staf f review and analysin performed in revising the 1977 SSR or in continuing the Statt's safety review.

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3) a) Would any of the conclusions reached by Staf f in the 1982 SSR remain valid, in Staff's opinion, if the CDA were demonstrated to be of suf ficiently high probability that it should be included within the design basis of the CRBR?

b) If the answer is yes, icentify and provide tne analysis upon which Staf f relies for its answer.

c) If the answer is no, identify each conclusion in the SSR which Staff would have to revise if the CDA were a DBA.

d) If Staff's answer is that it does not know whether a particular conclusion would need revision, describe what additional information Staff would need in. order to decide whether revision is necessary.

II.Section I

1) (I-2) Are the 1982 SSR conclusions still valid, to Staft's knowledge, if one assumes the reactor will be fueled by reactor-grade plutonium? If the answer is yes, describe in detail the analyses and data (including numerical results) that support Staft's conclusion that the site is suitable for a reactor using reactor-grace plutonium in its fuel assemblies. If not, explain in detail why such analyses have not been conducted.

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2) (I-4) Identity each " design parameter.that impacts upon the question of siter suitability" that is not specitically identified in the 3782 SSR.

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3) Intervenors would like an exp]anation of whicn aspects or parameters of the present CRBR design Staf f currently believes are adequ0te for purposes of site suitability; 4 which aspects or pa rameters req uire more Staf f review ,

betore their adegut,cy can be determined; and which aspects or parameters are not adequate as presently designeo.

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P] ease identify and describe each aspect or parameter of the present CRBR design which Staf f currently believes:

a) is adequate for purposes of determining site suitability; ']

b) wi)) require further technical or design information to complete the safety analyses and for which information will not be available until atter the Staf f completes the SER; c) is not adeq uate f or purposes of determining site '

suitability as presently designed, anc cannot feasibly I be made adequate; and l

l d) is nnt adequate for purposes of determining site suitability as presently designed, but which may be redesigned adequately, given the current state ot technology.

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8 If Staff is unable to answer any of these questions because its review is not complete, please provide any tentative or preliminary conclusions Staff may have. If Staff has no preliminary or tentative conclusions at this time for one or more of the above questions, indicate whether Statt intends to develop, or expects to reach any such conclusions before commencement ot the LhA-1 hearings.

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4) (I-4) Specify each and every statement in the May 6, 1976 letter, by sentence, wnich Staff presently considers a

" r eq u i r eme n t" with which Applicants must specifically comply. For each statement in the letter which Staff does not consider to be a " requirement," explain in cetail why compliance with such statement will not be req uired.

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5) (I-4) Identify and cescribe each Statt requirement with which Applicants must comply in order to demonstrate site suitability, other than the requirements indicated in response to Interrogatory 4 above, and those in 10 CFR

% Part 100.

III.Section II

3) (II-1) Explain in detail why Statt no longer describes the CRBRP pesign Criteria (SSR Appendix A) as " minimum req uirs.nents acceptable to the staf f f or the principal m

9 design criteria of the CRBRP," but now describes them as "an example of the kinos of req uirements acceptable to the staff for the principal design criteria of the CRBRP."

2) (II-1) Describe in detail the effect of tne cnange described in Interrogatory 2 above on Staf f 's CRBR site suitability review and what role, if any, the CRBRP Design Criteria will play during the LWA-1 hearings.

3) (II-2) Explain in detail why Staf t will no longer require Applicants to demonstrate compliance with the CRBRP Design Criteria, at the construction permit stage, but will instead " evaluate the applicants' specific engineering criteria and will require that any necessary modifications be made to these specific criteria to achieve satisfactory conformance with each of the principal criteria."

4) (II-1) Has Staff reached any preliminary, tentative, or final conclusions regarding the acceptability or any or the CRBRP Design Criteria included in SSR Appendix A? If so, identify and describe each such conclusion, and provide the basis for such conclusion. If the answer is no, indicate whether Staff intends to develop, or expects to reach, any such conclusions before commencement of the LWA-1 hearings.

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5) For each CRBR Design Criterion included in SSR Appendix A, and for each requirement included in the May 6, 1976 Denise-Caffey letter, indicate whether it is Staff's current assessment that such criterion or req uirement, a) is necessary in order to comply with 10 CFR 100; b) is sufficient in order to comply with 10 CRR 100; c) is necessary in order to assure a level of safety comparable to current generation light water reactor plants; d) is suf ficient to ensure a level of safety comparable to current generation light water reactor plants.

6) (II-2) Explain the present basis f or Staf f's statement that:

The Commission's regulations require that an applicant design, manufacture, and operate the plant to minimize the likelihood of accidents.

Does Staff believe that this requirement applies to the CRBR? If so, why does Staf f req uire only two redundant and I

diverse shu tdown systems?

7) (II-9) The Staf f states that " applicants have submitted the results of their analysis regarding the integrity of the hot leg, which is part of the current evaluation for the SER."

Il a) Identify, describe, and provide each analysis regarding the integrity of the hot leg piping that has been submitted by Applicants since January 1977, and any ano all documents related thereto.

b) Describe in detail the pre-service and in-service inspection program, material surveillance program and verification of each leak detection system performance for the CRBR referred to by Statt.

c) Describe in detail the nature of the research and development to verify material degradation procesces referred to by Staff.

d) Describe in detail why Staff believes a mere 20-25%

difference in temperature prevents Staff from considering the cold leg pipe rupture to be a design basis even in the same manner as it considers a hot leg pipe rupture, e) Describe in detail the analysis and documentation relied upon by Staf t for its conclusion that double-ended rupture of the CRBR primary cold leg piping could potentially lead to a CDA unless otherwise mitigated. Identify and provide all documents relied on by Staf f for its answer.

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8) (II- 10 ) Describe in detail (i) all the analytical work, and (ii) all the experimental work perf ormed at EBR-II concerning conditions that might arise during plant operations and that potentially affect fuel pin failure propagation. Identity and provide all documents related to such analytical or experimental work.

a) With regard to each analytic and experimental work described above, identify the specific document (s) tha t f orm(s) the basis for Staf f's current statement that: -

The results of this work thus far indicate that there should not be a significant potential for failure propagation beyond a few fuel-pins under the anticipated operation conditions and limitations.

9) (II-10) Identify and describe in detail a) all the experimental wor k , and b) all the analytical work that has been conducted on the ef fects of blockages within a pin bundle.

Identify and provide any and all documents related to such analytical or experimental work.

10) (II-10) With regard to each analytical and experimental work described in response to Interrogatory 9 above, identify the specific document (s) that form (s) the basis for Staff's current position that:

13 a) the results, thus far, indicate that substantial blockages at the non-tuel inlet or outlet regions do not csuse overheating; b) inert planar blockages covering a few coolant subchannels in the fuel region do not cause any significant overheating; c) small heat-producing (fuel material) blockages do not cause significant overheating of adjacent areas; d) there is a substantial basis to anticipate that local f aults af fecting single or a few pins within a subassembly will not rapidly propagate to adjacent pins.

II) (II-11) Describe in detail the basis for Staff's conclusion that " fuel pin f ailures which might occur under various plant operating conditions, including design transients, are unlikely to create conditions under which significant fuel failure propagation within a subassembly would occur."

12) (II-10, II-11) Explain in detail how Staf f was able to reach the conclusion described in Interrogatory 12 above in light of the fact that "the current staf f position is that of not being yet convinced that the staf f rea uirements regarding subassembly propagation have been satisfied."

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13) (II-10) Explain in detail whether Staf f believes that the "more sensitive and faster response monitoring systems" that Staf f may req uire a) are feasible to design, install, and maintain; b) will be suf ficiently numerous adequately to cetect subassembly faults; c) will be sensitive ano q uick enough adeq uately to detect subassembly faults.

14) (II-20) Explain in detail the basis for Staff's revision of the 1977 SSR Table I (p. II-3 8) by removing the section entitled " Additional Features Proposed for Accommodation of Core Melt and Disruptive Accidents" (II . D .4) .

a) Are Applicants still proposing these additional features for accommodation of core melt and disruptive accidents?

b) If so, nave Applicants revised these proposals in any l

l way? Identify and provide all such revised proposals, l

and any and all documents related thereto, c) If applicants are no longer proposing the features as described in the original Table I, explain in aetail what features Applicants propose to accommodate core melt and disruptive accidents. In particular, describe in detail the features described in 1982 SSR, p. II-19 (first full paragraph). Identity and provice all documents related to Applicants' proposal (s) and Staf f's review to date of such proposal (s) .

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15) (II-19) Describe in detail and provide the documentation upon which Staf f relies at the LWA-1 stage f or its conclusion that "other feasible design features...

separately or in combination could reduce the probability of containment failure to an acceptable level."

16) (II-18) Identify each " alternative criterion for evaluating core melt accidents, in lieu of the 24-hour criterion" currently under evaluation by Staf t.

a) Explain in detail why Staff believes such an evaluation is necessary.

b) Explain whether each alternative criterion under evaluation by Staff is more or less stringent than the 24-h our criterion, and give the basis for your answer.

c) Staf f has based its 24-hour criterion on the NASH-1400 conclusion that "most LWR core melt accidents do not result in early (less than one hour) containment failure, but may involve sucn failure within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." To wha t extent , if any, is this conclusion consistent with the recent analysis performed by Oak Ridge National Laboratory concerning the probability ot severe LWR core-melt accidents (see Nucleonics Week, July 8, 1982, pp. 1-2)?

17) (II-17) Explain fully the basis for Staf f's view that a technically feasible solution to accommodate sodium pipe breaks is to increase the RCE design pressure to 50 psig.

16 a) Identify all LWR containments that use 50 psig or larger pressures as a design basis.

b) To what extent does this solution depend on the incorporation of other features (e.g., filtered vent systems, containment pu rge, core ca tcher) ?

18) (II-19) Staff indicates that the " technology exists to design and build such devices" to accommodate excessive mechanical loads, a) Does Staf f believe this statement applies to work energies (to 1 atm) up to 1200 mj?

b) Does Staff believe this statement applies to work energies (to 1 atm) exceeding 1200 mj?

c) If the answer to (b) is yes, a t approximately what CDA energetic level does Staf f no longer have confidence that it is technically feasible to design and build a primary containment to withstand such an accident for the CRBR or a reactor of the general size and type as the CRBR?

19) (II-19) Describe as fully as possible each " reactor head design" examined by Staff with regard to whether it was a "potentially workable design" which could "be used to implement the Staf f 's containment protection r eq u iremen ts. " Identify and produce all documents examined by Staff where these alternative head designs are

a.

17 (i) described and (ii) analyzed.

20) (II-19) Identify each alternate head design that is a "potentially workable design."

21) (II-19) When Staf f refers to a "potentially workable design," what is the largest CDA energetic level that the design must be able to accommodate and still be considered potentially workable?

22) Identify and produce any and all analyses examined and relied upon by Staff for purposes of establishing the energetics of the CDA, in order to establish the benchmark or criteria fot judging whether the CRBR bead design, or alternate head designs, are "potentially workable designs."

a) If no analyses were relied upon, explain fully how Staff can conclude that a particular head design is "potentially workable" without knowing what mechanical loads it might be req uired to accommodate.

IV. The following interrogatories are related to the dose calculations appearing in Table IV (III-11).

1. Intervenors wish to reproduce the results in Table IV, but Table IV does not present all the assumptions used to calculate the dose consequences for the exclusion area ana

18 low population zone. Identify each and every assumption, inc]uding a) each model eq uation and b) each input parameter, together with the basis for the choice of each assumption (eq uation and input value) . Provide the source of each equation and each input parameter cited (PSAR, ER, Regulatory Guide, e tc. , with the appropriate page nu mber s) . If a computer code is utilized (e.g . , CRAC or TRAC) , provide a printout of the code and all input and outpu t da ta , together with a detailed description of the input and output f ormat, and any documentation of the computer model.

2. With regard to each model assumption and input datum identified in 1 above, is Staff aware of any alternative model(s) or source (s) of input data or other assumptions that could result in higher aose consequence results? If so, please identity and explain the basis for rejecting these models or data. Intervenors are seeking to determine whether newer models, such as the ICRP lung model or alternative meteorological data, were considered by Staff, as wel] as the basis for their rejection.

3. What is the basis for the choice of the primary containment leak rate (0.1%/ day) and the bypass fraction (0. 001%/ day) ? What is the source for these assumptions; i.e., where are they documented? Identify and provide all such documentation.

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4. Will Applicants be required to demonstrate the primary containment leak rate (0. 3% vol/ day) and the bypass fraction (0.003% vol/ day) through testing alone (see p.

II-15, which refers to technical specifications and testing)? If so, explain how this requirement will be applied. How does Staf f determine Nhether tnis value is correct or conservative? Does Staff consider these rate and bypass fraction values to be firm requirements? If not, explain why not.

5. Does Staff consider the bypass fraction ( 0. 0014/d ay) to be conservative? Explain in detail the basis for Staff's a ns wer .

6. Has Staf f conducted any analysis of a) the CRBR containment design b) the containment design of a reactor of the general size and type as the CRBR to assure itself that the bypass fraction assumption is appropriate?

If so, please document fully the nature of such analyses and identify all documents (cite appropriate pages) considered in each analysis.

7. Has Staff conducted or examined any sensitivity analyses to determine how the dose consequences vary with cnanges

20 in the primary containment leak rate and bypass traction?

If so, identify and provide all such analyses anc results and all documents related thereto.

8. What is the basis f or Staf f's choice of the values for the annulus filtration system flowrates (3,000 cfm and 11,000 c f m) ? a) Why were these values increasea over the values presented in the 1977 Site Suitabiity Report? b) What is the source f or these new assumptions; i.e. where are they documented? Identif y and provide all such documentation.

9. Will Applicants be req uired to demonstrate these flow rates through testing? If so, explain in detail how this req uirement will be applied. How does Staf f assure itself that these values are correct, or conservative? Are these flow rates firm requirements? If not, why not?

10. Does Staf f consider these flow rate values to be conservative? Explain in detail the basis for Staft's ans we r .

11. Has Staff conducted or examined any sensitivity analyses to determine how the dose consequences vary with changes in the exhaust and recirculation filtration system flowrates? If so, identify and provide all such analyses and results and all documents related thereto.

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12. Explain in detail the basis for Staff's choice of the values for the aerosol fallout coefficients in containment. Identify and provide all documents used by Staff in forming these asumptions.

13. Does Staf f consider the aerosol f allout coef ficients to be conservative? Explain in detail the basis f or Staf f's ans we r .

14. Explain in detail the basis for Staff's choice of atmospheric dispersion parameters.

a) Wnat is the source f or these new values?

b) Identify and provide all documents used by Staf t in developing these values.

c) Why were the values increased over the values utilized in the 1977 Site Suitability Report?

15. What period of time (initial day /mo/yr to final day /mo/yr) is represented by the atmospheric dispersion parameters?

j 16. Have Applicants collected meterological data during other periods of equal length (e.g., I year) that Staff believes would be adequate for purposes of calculating atmospheric dispersion parameters f or the CRBR site?

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17. Over what period does Staf f believe Applicants have collected meteorological data that would be adequate for purposes of calculating atmospheric dispersion parameters for the CRBR site?

l 18. Does Staff take the position that Statf or Applicants are free to choose the time interval (i.e. beginning and ending dates) which gives the smallest X/O values, provided the length of the time interval and all other considerations meet Regulatory Guide 1. 345 req uirements?

Explain in detail the basis for Staf f's answer.

19. Does Staff believe the X/Q values in Table IV are conservative in light of Applicants' choice of the time interval (i.e. beginning and ending dates) for analyzing meteorological data? Explain in detail the basis for Staff's answer.

20. Why doesn' t Staf f req uire or utilize an analysis of the l

entire time interval during which adequate meteorological data is available for purposes of calculating X/Q values?

21. Approximately how many years o,f site meteorological data does Staff believe one would need in order to have j reasonable confidence that the derived atmosphere

23 dispersion parameters are representative of future meteorological conditions expected for the site? Explain in detail the basis for Staff's answer and identify and provide all documents upon which Staf f relies for its an s we r .

a) Does this answer represent, in Staf f 's view, the. expert opinion of meteorologists? Explain the basis for Staf f 's answer, and identify and provide all documents upon which Staf f relies f or its ans wer.

22. What model(s) were used by Staf f to calculate the organ doses (in rems) per curie of activity inhaled and for external and exposures? Identify and provide all documents upon which Staff relies for its answer.

23. What plutonium isotopic content did Staf f assume would be used to fuel the CRBR? a) Did Staff examine the effect on oxygen dose calculations of switching f rom f uel-grade to reactor-grade plutonium? If the answer is yes, provide the results of that analysis in full, and any and all documents related thereto.

24. Does Staff consider its assumptions regarding the Pu isotopic concentration to be conservative in light of the possible future use of reactor-grade plutonium in CRBR fuel? Explain in detail the basis for Staf f 's answer.

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25. Wha t assurance , if any does Staf f have that reactor-grade plutonium a) will not be used as fuel for the CRBR; b) will be used as fuel for the CRBR.

Identify and provide any and all documents relied upon by Staff for its ansher.

26. What assumptions were made with regard to the delay time between initiation of the event (i.e., source term release to the reactor containment building) and the activation of the confinement annulus filtration system? What is (a r e) the basis (bases) f or the assumption (s) ?

27. What assumptions were made with regard to whether the by-pass leakage fraction escapes.directly to the environment or to the reactor service building (RSB)?

a) What assumptions were made regarding~ the extent to which this leakage component is processed through the RSB filters before escaping to the environment?

28. What assumptions were made with regard to the attenuation mechanisms inside the containment for a) iodines; b) solid fission products; and I

c) plutonium?

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29. What assumptions were made with regard to the attenuation mechanisms outside the containment for a) iodines; b) solid fission products; and c) plutonium?

30. Are the same aerosol fallout coefficients cited in Table IV applied to each of these assumed core fractions and those indicated in Interrogatories 28 and 29?

31. Why were transuranic elements, other than plutonium, excluded from the site suitability source term?

a) What is the basis for excluding transuranic elements?

b) What is the basis for Staf f's belief that plutonium would adequately serve as a surrogate for americium, curium, e tc.?

c) How would the doses change if the SSST included 1% of the transuranics as well as 1% of the plutonium?

d) What sensitivity analyses has Staf f conducted to determine the effect of excluding these other transuranic elements? Identify and provide all such analyses and results.

32. What assumptions were made in Table IV, if any, with regard to wind meander?

a) How is wind meander treated (implicitly or explicitly) in the X/Q calculations?

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26 b) Was a wind meander factor applied? If so,_ identify and describe this factor. q

33. .What assumptions are made with regard to LPZ dose l

i commitments beyond 30 days?

I a) What is the basis for these assumptions? j 1

1 b) Did Staff arbitrarily assume that all the remaining plutonium in containment is released as a puf f at 30 4 days?

c) What fraction of the total LPZ lung and bone 50-year dose commitments are due to releases in the first 30 days, where total dose commitment implies integration j

- of the release for a period much greater than 30 days i

, (e.g., until essentially all of the plutonium aerosol is released or otherwise unavaila~ole because of f allout) ?

d) How does the over-30-day exposure compare to the 0-30 day contribution?

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j 34. What assumptions are made with regard to dose commitments.

i via pathways involving exposure following ground contamination? Explain in detail the basis for Staff's

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4 an s we r .

I a) _ Has Staf f conducted any analysis in this regard? If so, identify and provide all such analyses and any and all documents related thereto.

l I. __ . . _ _ _ . . _ _ _ _ _ - _ _ _ _ _ . _ . . _ _ _ _ _ _ . . _ . . _ _ , _ _ , _ . . _ _ _ _ _ _ , _ __. _

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35. What breathing rates were assumed for Table IV?

36. How were the inhalation dose f actors (r em/Ci Inhaled) calculated for a) thyroid; b) whole body; c) Jung; ,

d) bone surfaces?

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37. For the whole body and each organ considered, provide a table showing the dose (commitment) contribution te each due to each separate source term contribution (noble gases, halogens, solid fission products, plutonium, and sodium) . Provide separate tables for the exclusion area dose and the low population zone dose commitment.

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38. Provide a table of the CRBRP heavy metal inventory (all U, Np, Po, Am, Cm, and Cx isotopes) in curies for EOEC conditions.

39. Provide a table of the aerosol depletion f actor (fraction /sec) as a function of time for the various SSST core fractions.

28 V.Section III

1. (III-9, 30) In application of the ICRP 26 methodology:

a) Explain fully the basis for Staff's rejection of the weighting factors proposed by EPA in favor of those recommended by ICRP.

b) Explain fully the basis for Staf f's decision to use a mor.tality risk eq u ivalent whole body dose rather than a morbidity risk eq uivalent whole body dose.

c) Explain fully the basis for Staff's decision not to incorporate the concept of organ dose " caps" to protect against non-stochastic ef fects, d) Explain fully the basis for Statf's decision not to utilize the recommendations by EPA in EPA 520/4-77-016,

" Proposed Guidance on Dose Limits f or Persons Exposed to Transuranium Elements in the General Environment,"

to protect against risks associated with accidental ground contamination by transuranic elements.

e) In the 1977 SSR, Staff accounted for uncertainties noted in Section B of Regulatory Guides 3.3 and 1.4 by recucing the lung and bone dose guidelines by a factor of 10 for use at the CP review stage (1977 SSR, p.

III-16). In the 1982 SSR (p. III-9), much smaller factors are applied to account for uncertainties regarding lung and bone (surface) doses. Isn't the

O 29 ef fect of the new Staf f methodology to reduce the lung and bone factor (i.e., the factor to account for uncertainties at the CP stage) from 10 to approximately 27 f) Explain fully the underlying basis f or constructing a methodology that has the ef fect of reducing the f actors of conservatism to account for these uncertainties, g) In application of the "ICRP 26 methodology" doesn't Staf f's use of 34 rem at the OL stage and 24.5 rem at the CP stage have the effect of accounting for the whole body and thyroid dose uncertainties and ignoring completely the uncertainties associated with lung and bone surface doses? If Staf f disagrees, explain fully the basis for such disagreement.

2. (III-10) What is the basis for Staff's conclusion that "an effectively coordinated site, state and local radiological emergency response plan can be achieved f or the Clinch River Site?"

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3. (III-10) Explain fully the basis for Staff's statement tha t ORGDP, ORNL, and Y-12 can be effectively evacuated withou t undue risk to national or energy security?

4. (III-10) To wha t extent , if any, are Staff's conclusions on this page dependent on the assumed SSST and dose consequence analysis?

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5. (III- 10) How long could the Y-12 f acility remain evacuated without adversely affecting national security?

Respectfully submitted, r ;-

Ellyn 4t. Weiss 57

(

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HARMON & WEISS 1725 Eye Street, N.W.

Washington, D.C. 20006 (202) 833-9070

!T - Y Tarbara A. Fin ~amore

=l ef S. Jacob Scherr Natural Resources Defense Council, Inc.

1725 Eye Street, N.W.

Washington, D.C 20006 (202) 223-8210 Attorneys for Intervenors Natural Resources Defense Council, Inc.

and the Sierra Club Dated: July 13, 3982 Washington, D.C.

49 t

y i . . ,. ,

CERTIFICATE OF SERVICE 3 F 4 c3 f' ' O _ U. a I hereby certify that copies of NATURAL RESOURCES' DEFENSE.- '

COUNCIL, INC. AND THE SIERRA CLUB TWENTY-SIXTH SET OF INTERROGATORIES TO STAFF and LETTER TO THE COMMISSIONERS DATED JULY 12, 1982 REGARDING CLINCH RIVER BREEDER REACTOR PLANT DOCKET NO. 50-537 were served this 13th day of July 1982 on the following:

• Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway Bethesda, Maryland 20814

• Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway Bethesda, Maryland 20814

• Daniel Swanson, Esq uire l

Stuart Treby, Esquire Bradley W. Jones, Esquire Of fice Of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, Maryland 20814

• Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (3 copies)

• R. Tenney Johnson, Esq uire Leon Silverstrom, Esq uire Warren E. Bergoholz, Jr., Esguire Michael D. Oldak, Esq uire L. Dow Davis, Esq uire Office of General Counsel U.S. Department of Energy 1000 Independence Ave. , S.W.

Washington, D.C. 20585

• George L. Edgar, Esq uire Irvin N. Shapell, Esquire Thomas A. Schmutz, Esq uire Gregg A. Day, Esq uire Frank K. Peterson, Esq uire Morgan, Lewis & Bockius 1800 M Street, N.W.

Washington, D.C. 20036 Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California P.O. Box 247 Bodega Bay, California 94923 Herbert S. Sanger, Jr. , Esq u ire Lewis E. Wallace, Esq uire James F. Burger, Esq uire W. Walker LaRoche, Esq uire Edward J. Vigluicci Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 William M. Leech, Jr., Esq u ire Attorney General William B. Hubbard , Esq uire Chief Deputy Attorney General Lee Breckenridge, Esquire Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219

e Lawson McGhee Public Library 500 West Church Street Knox;r';11e, Tennessee 37902 William E. Lantrip, Eg uire City Attorney Municipal Building P.O. Box 1 Oak Ridge, Tennessee 37830 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 32219 arbara A. Finamore

• Denotes hand delivery.

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