ML20058J734

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Supplememtal Responses to Eighteenth,Nineteenth & First Set of Interrogatories Re Listed Contentions & to Requests for Identification of Witnesses.Certificate of Svc & Affidavits Encl.Related Correspondence
ML20058J734
Person / Time
Site: Clinch River
Issue date: 08/06/1982
From: Edgar G
EDGAR, G.L., ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP., TENNESSEE VALLEY AUTHORITY
To:
National Resources Defense Council, Sierra Club
References
NUDOCS 8208110190
Download: ML20058J734 (41)


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UNITED STATES DEPARTMENT OF ENERGY ) '/j 7,f

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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

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TENNESEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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SUPPLEMENTAL RESPONSES TO NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB DISQOVERY REQUESTS Pursuant to 10 C.F.R. Part 2.740(b), and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy and Project Management Corporation, for themselves and on behalf of th'e Tennessee Valley Authority (the Applicants), hereby provide supplemental responses to the Natural Resources Defense Council, Inc. and the Sierra Club discovery requests.

Supplemental Responses To Eichteenth Set of Interrocatories I. Contentions 1, 2, and 3 INTERROGATORY

16. Identify precisely upon which portions, in whole or in part, of the PSAR and other documents (including but not limited to CRBRP-1, CRBRP-2, CRBRP-3, CRBRP-GEFR-00523, WARD-D-0118, NEDM-14082) Applicants intend to rely at the LWA-1 stage in order to demonstrate:

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a. that the CDA should be excluded from the design basis; and
b. that the source term selected for CRBR is suitably conservative for purposes of Part 100.

RESPONSE

The Applicants incorrectly identified the existence of documents that estimated the probability for core melt for CRBRP (Deposition of George H. Clare, Neil W. Brown and L. Walter -

Deitrich, Wednesday, June 16, 1982, p. 53, lines 21 and 22, "Q. Do you know any other estimates for the probability for core melt for CRBRP?"). The response to this question should have been "No". The five subsequent questions on pp. 54 and 55, which inquire about knowledge Mr. Brown might have had concerning the incorrectly identified documents, are no longer valid based on an answer of "No" to the identified question. The documents identified previously are the only ones responsive to the interrogatory.

I. Contentions 1, 2, 3 -

  • INTERROGATORY I
19. Provide all documents,1 memoranda, or communications in any form between or among Project Management Corp., TVA and DOE ,

related to the following subjects:

a. the risks of a CDA for the CRBR;
b. the risks of a CDA for a reactor of the general size and type proposed; l

1Documents requested were limited t'o the time period between January 1, 1976 and June 1, 1977. .

I

, , c. the consequences of a CDA for the CRBR;

d. the consequences of a CDA for a reactor of the general size and type proposed;
e. the source team for the CRBR;
f. the source term for a reactor of the general size and type proposed;
g. the decision to withdraw the " parallel design";
h. the potential changes to the CRBR design or site that might result from including the CDA within the design basis;
i. the potential cost of such changes to the CRBR design or site; and
j. the suitability of the CRBR site.

INTERROGATORY

20. With respect to the subjects covered by (a)-(j) above, Project Management Corp., DOE and TVA shall each provide any internal memoranda, minutes of meetings (including but not limited to Board meetings) or documents 2 of any kind bearing on those subjects.

e RESPONSE The following additional document is available for inspection and copying at the Office of General Counsel, Department 2Documents requested were limited to the time period between January 1, 1976 and June 1, 1976.

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of Energy: Draft Report ANL/ RAS 77-15, May 1977, An Analysis of the Unprotected Loss of Flow Accident in the Clinch River Breeder Reactor with an End of Equilibrium Cycle Core, W. R. Bohl, et al.

Contact Warren Bergholz (252-6975) to arrange for inspection and copying.

IV. Contention 5 INTERROGATORY

1. Provide the information requested below for each of the following facilities:
a. Oak Ridge National Laboratory;
b. Y-12 Plant;

, c. K-25 Plant (Oak Ridge Gaseous Diffusion Plant);

(1) Describe the national security function (s),

if any, performed at each facility.

(2) If an evacuation of such a facility were re-quired, how many people would be required to remain at each facility for national security, or other reasons if the dose to such people j were likely to reach:

I l (a) 1 rem; ,

l (b') 5 rems; (c) 25 rems; (d) 100 rems; (e) 250 rems;

. , (f) 500 rems. .

(3) Identify fully the national security impact, if any, of losing access to each facility:

(a) for one' week; (b) for one month; (c) for three months; (d) for six months; (e) for one year; (f) indefinitely.

RESPONSE

1. The Oak Ridge National Laboratory is a research and development facility with no national security activities. '

The Oak Ridge Gaseous Diffusion Plant (ORGDP) enriches uranium in the isotope U-235, up to 4.0% assay, almost exclusively for commercial nuclear power reactors. In addition to these production activities, significant development work is conducted on advanced isotope separation technologies. Development of these technologies is also intended for meeting future enriched uranium requirements for power reactors. In our opinion, no functions are~

conducted at the ORGDP which can be construed as af fecting national security.

The Oak Ridge Y-12 Plant is a major facility within the Department of Energy's (DOE) nuclear weapons production complex.

The Plant produces components and subassemblies in support of the

4 production of nuclear weapons delivered by DOE to the Department of Defense. The Plant also produces components used in the nuclear weapons development and testing programs carried out by the three DOE nuclear weapons design laboratories.

2. We have not done the analysis for the specific dose levels indicated. We have completed an analysis for the SSST (see response to Interrogatory 3 below) . In the event of a release of radionuclides in a range that would require evacuation of all but essential personnel, the numbers of personnel likely to remain on-site would be as follows:

ORNL - 60 ORGDP - 65 Y-12 Plant - 250 1

The Applicants are presently engaged in an analysis of the effect of an HCDA on the three facilities. The results of that i analysis will be made available to Intervenors when it is completed.

3. The Applicants have not done detailed analyses of the i

national security impact of losing access to each facility for long term durations of time. Since the Y-12 Plant is the only facility of the three specified that performs national security activities, this question does not apply to ORNL or the ORGDP.

  • The Y-12 Plant is located approximately ten miles f rom the CRBR.

At this dis'tance it can be inferred from the radiation dose data graphed for the SSST (see attachment) that the projected radiation doses received after reentry only a few hours af ter the release would be well within occupational standards and no l evacuation would be required.

The impact of the SSST accident scenario on Y-12 Plant operations would be insignificant in regard to DOE's ability to meet l its national security commitments.

i

. , 1 The Project has evaluated the national energy impact of a shutdown of the ORGDP. The evaluation conducted in 1976, concluded that there would be no impact on military requirements in the event of a hypothetical shutdown, but there would be a reduction in the ability to supply fuel to domestic nuclear power plants. The answer of Mr. Wayne Hibbitts at his deposition that no such evaluation was conducted is in error. (Transcript of Kripps and Hibbitts deposition at pp. 72 and 81, June 21, 1982.)

Contention 7 INTERROGATORY

23. Provide all documents, analyses, calculations, evaluations, etc., related in whole or part to the question of the likelihood that CRBR will meet its programmatic obj ective.
24. Provide all documents, memoranda or communications in any form between or among Project Management Corp., TVA and DOE related to:

(a) the cost of constructing CRBR; (b) the cost of operating CRBR; l (c) the construction schedule for CRBR; (d) the likelihood that CRBR will meet its programmatic obj ectives; (e) the potential reliability of CRBR; (f) the environmental impacts associated with CRBR; (g) the potential technical perf ormance 3 . ... ,

, , of CRBR; (h) the cost of a core catcher for CRBR; '

(i) the cost of prohibiting venting of the -

containment building; (j) the cost of requiring CRBR to be able to contain energetic energy exceeding 661 megajoules, 1200 megajoules, or anything greater; (k) the possibility of terminating the CRBR project if it is or becomes too costly or is delayed.

25. With respect to the subjects covered by' (a)-(k) above, Project Management Corp., TVA and DOE shall each provide any internal memoranda, minutes of meetings (including but not limited to Board meetings) or documents of any kind bearing on those subj ects.

RESPONSE

The f ollowing documents relating to CRBRP site meteorological calculation (Interrogatories 23-25 (f)) are available for inspection and copying in the Office of General Counsel, United States Department of Energy. Contact Warren Bergholz (252-6975) to make arrangements for inspection and copying.

DATE TO/FROM SUBJECT 9/5/80 K. Yates, PMC/ Preliminary X/Q values for the i

L.L. Simmons, EIA permanent meteorological tower.

, 10/1/80 K. Yates, PMC/ X/Q calculations using the l L.L. Simmons, EIA permanent meterological tower l February 19, 1977 through February 16, 1978 l

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10/17/80 W.J. Purcell, W-CR CRBRP (X/Q) Meteorological M. C. Ascher, B&R/ Dispersion Factors R.L. Copeland, PMC ,

10/21/80 K. Yates, PMC/ X/Q Procedures L.L. Simmons, EIA 2/21/81 K. Yates, PMC/ Comparison of Temporary ,to L.L. Simmons, EIA Permanent Tower Meteorological Data 11/5/81 K. Yates, PMC/ Response to TVA Questions On A. Roffman, EIA . Meteorological Calculations VI. Contention 8 INTERROGATORY 4

1. Have any analyses been undertaken of neutron activation products which Applicants rely upon to determine:
a. the potential isolation period of the CRBR following decommissioning?
b. the-economic costs of decommissioning the CRBR?
c. the environmental costs of decommissioning the CRBR?

l l d. the societal costs of decommissioning the l CRBR?

If the answer to any part of this interrogatory is yes, identify and produce such assessments and any and all documents in the possession l of Applicants relating thereto.

INTERROGATORY

2. If the answer to any part of the above interrogatory is that Applicants do not rely on any analyses of neutron activation '

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. . products, explain in detail why Applicants believe that reliance on such analyses is unnecessary.

RESPONSE

Delete the original responses and insert the following:

In connection with.NRDC Contention 8, Applicants have completed and now intend to rely upon analyses of dose rates for Ni-59, Nb-94 and Co-60. These analyses are described in Attachment A hereto. Using the analytic methods described in Attachment A, the Applicants have also calculated the upper bound values of specific activity for certain CRBRP components as described in Attachment B.

Supplemental Responses to Nineteenth Set of Interroaatories Contentions 1, 2. and 3 INTERROGATORY

27. Will Applicants rely upon "probabilistic analyses of CRBRP accident risks and/or consequences" in any way during the LWA-1 proceeding? If the answer is yes, describe each analysis, portion of analysis, or other factor, including the existence and general characteristics of such analysis, upon which Applicants intend to rely.

RESPONSE

Applicants do not intend to rely upon an adequate, comprehensive analyces comparable to the Reactor Safety Study

("Rasmussen Report") that could identify CRBRP accident possibilities of greater frequency or consequence than the accident scenarios analyzed by Applicant and Staff in the LWA-1 proceeding.

NRDC has advised the Applicants (NRDC letter of July 28, 1

1982) that it defines probabilistic analyses as "any quantitative probabilistic or quantitative reliability data of CRBRP accident risks or consequences". NRDC had previously advised the Applicants that the term "probabilistic analysos", as used in the interrogatory, means:

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(1) Anything that address as the probability of i failure in a quantitative manner; or (2) Anything that provides gaantitative support for qualitative assessments of the likelihood of failure.

The Applicants do not intend to rely on "any quantitative probabilistic or quantitative reliability data of CRBRP accident risks or consequences" under the assumption that this means quantitative data resulting from reliability or probability analyses undertaken to determine the failure rate or probability of failure or probability of consequences. As previously indicated, Applicants do not intend to rely upon any quantitative reliability data from reliability program set forth in Appendix C to the PSAR.

Contention 4 INTERROGATORY

35. What specific f actors lead to the conclusion that co-location would not result in a significant impact on saf eguards effectiveness (agg Applicants' Updated Response to 12th Set of Interrogatories, p. 47) ? ,

RESPONSE

The specific factors which lead to the conclusion that co-location would not result in a significant impact on safeguards effectiveness are presented in Section 5.7.1.5 of the CRBRP Environmental Report (.sgg pages 5.7-48 and 5.7-49 discussing

transportation of fresh MOX fuel and pages.5.1-49 and 5.1-50 discussing spent fuel transportation).

Contention 7 INTERROGATORY .

48. Have Applicants performed any analyses of the following alternative sites during the LMFBR demonstration plant site selection process:
a. TVA Hartsville site?
b. TVA Yellow Creek site?
c. Washington Public Power Supply System (WPPSS) Unit 4 site?

If the answer is yes, identify and provide all such analyses and all documents in the possession of Applicants relating to such analyses. Describe the conclusions reached by Applicants and explain in detail the basis for all such conclusions. If the answer is no, explain whether Applicants intend to perform such analyses, and, if not, why not.

RESPONSE

The Hartsville (Johntown) site was considered in the

) Applicants' original alternative siting analysis Otte Environmental Report Section 9.2 and Appendix A). The Yellow Creek site was not included in the original analysis because of the seismic design uncertainty in the western end of the TVA system at the time of the analysis. Both sites are considered as alternative candidate sites in the Applicants' " Update to the CRBRP Alternative Siting Analysis Within the TVA Power Service Area" LEgg Appendix G of the Environmental Report -- an advanced copy of Appendix G will be made available for inspection and copying) .

The Washington Public Power Supply System (Supply System)

Nuclear Unit 4 (WNP-4) has been considered in the Applicants'

" Supplemental Alternative Siting Analysis Update f or the LMFBR Demonstration Plant" (agg Attachment 2 of the letter from J. R.

Longenecker to Public Saf ety, dated February 12, 1982, Section 2.11.14).

The conclusions reached by the Applicants and the basis for these conclusions are contained in the above noted alternative site analyses.

Supplemental Responses To First Set of Interroaatories INTERROGATORY

7. Identify all documents, reports, memoranda, etc.

generated by the Applicants or in their possession related to the potential problems of sabotage or terrorist activity directed at CRBR or any fuel cycle activities needed to support it.

RESPONSE

The following document is hereby added to the list of documents in Attachment C to Applicants' April 30, 1982 Updated Response to Natural Resources Defense Council, Inc. and the Sierra Club First Set of Interrogatories to Applicants:

FMEF - Costs of Physical Protection l Components, April 2, 1982.

Supplemental Response To l Seventh Recuest For Documents REOUEST l

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3. Letter, D. Clark Gibbs to Mike McCormack, re: breeder reactor technology, dated March 26, 1980.

RESPONSE

The requested document has been located and is available for inspection and copying at the Office of General Counsel, Department of Energy. Contact Warren Bergholz (252-6975) to make arrangements for inspection and copying.

Supplemental Response To Recuests For The Identification of Witnesses -

Applicants have identified the following witnesses:

Contentions 1, 2. and 3 (exceot 2fe))

George Clare Neil Brown Walter Dietrich Lee Strawbridge Vincent S. O' Block Copies of Statements of Prof essional Qualifications for Messrs.

Clare, Brown and Dietrich have previously been furnished to NRDC at the time of their deposition. Mr. Strawbridge's Statement is attached. Mr. O' Block's Statement will be furnished within the next week.

Contention 4 Edward Penico l 1

l Thomas Isaacs Mr. Penico's Statement was previously furnished to NRDC at the time of his deposition.

Mr. Isaac's Statement will be furnished within the next week.

Contentions 5 and 7(c)

Lawrence Kripps (5 (a) and 7(c))

Wayne Hibbitts (5(b))

Lee Strawbridge (5(b))

Copies of Statements of Messrs. Bibbitts and Kripps were previously furnished to NRDC at the time of their deposition. As noted above, Mr. Strawbridge's Statement is attached.

Contention 7(a) and (b)

John Lcngenecker Dr. Carl Anderson '

Dr. Narinder Kaushal A copy of Mr. Longenecker's Statement is attached. Mrssrs. Anderson and Kaushal's Statements will be f urnished within the next week.

Contention 6 George Sherwood William Hartman Douglas Hornstra

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Douglas Hornstra Owen Yarbro I Carl Newton '

Copies of Statements of Messrs. Sherwood, Hartman, Hornstra and Yarbro were previously furnished to NRDC at their deposition. Mr.

Newton's Statement will be furnished within the next week.

Contention 8 Richard Disney Mr. Albert A. Weinstein James F. Murdock Copies of Statements will be furnished within the next week.

Contention 11 Dr. Julian Preston (11(b))

Dr. Roger McClellan (2(e) and'11(d) at Phase I hearings)

Dr. Roy Thompson (2(e) and 11(d) at Phase I hearings)

John Healy (2(e) and 11(d) at Phase I hearings)

Copies of Statements will be furnished within the next week.

Additional witness identities and their professional

qualif1 cations will be furnished as soon as the information is available.

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ATTACHMENT A Ni-59, Nb-94 and Co-60 Dose Rate Calculations Dose Rate From Ni-59 The dose rate from Ni-59 can be calculated by detemining the buildup of the isotope during operation of the reactor, by evaluating an energy and spatially dependent radiation source from its frequency and spectraum of decay, and by analyzing the transport of the emitted radiation through I

the key reactor components to a dose point.

,N-9 i5 Inventory _

~

Ni-59 is created by neutron capture in Ni-58, a parent isotope com-prising 67.76% of the natural nickel found in the stainless steel alloys from which the permane'nt structural components of the CRBRP that could become activated by neutron irradiation are to be fabricated. These com-ponents include the fixed radial shield (FRS), the core lower support structure (LSS), core barrel (CB), suppressor plate (SP), thennal liner (TL),

reactor vessel (RV), and the guard vessel (GV). The inventory of Ni-59 in the CRBRP can be calculated by considering the Ni-58 capture rate 3

.(captures /cm -s' e cond) in the pemanent structures, and integrating this volumetric capture rate over the structure volume. A conservative estimate of the Ni-59 activity at any point in the CRBRP system is calculated by as-suming the following:

3

1. The Ni-58 atom density, nuclei /cm , is not depleted by neutron capture.
2. The neutron flux level, neutrons /cm2 -second, is constant at the full power operating condition.
3. Loss of Ni-59 due to radioactive decay of Ni-59 is in-4 significant due to the long half life of 8.0 x 10 years, l

Therefore, the Ni-59 density, nuclei /cm3 , present in the pem-anent structures at the end of the CRBRP operations, is:

(1) Bj = Aj $j(E) oA(E) T dE where: Bi = nuclei /cm3of Ni-59 at point i at completion of CRBRP operations, 2

41(E) = particle flux of neutrons With energy E, neutrons /cm ,

second at point i, 2

cA(E) = neutron capture cross'section, cm , for production of Ni-59 due to neutrons of energy E.

3 S8 Aj = nuclei /cm of Ni at point i, .

T = total operating time of CRBRP reactor,22.5 effective full power years.

The method used to calculate the Ni-59 production involves a multigroup

. approximation of the neutron energy dependence of the capture rate. The (

neutron flux distribution, +gi, in each of 42 neutron energy groups was detemined in a DOTIIIW two dimensional discrete ordinates transport theory solution based on a model of the CRBRP system. Figure 1 shows the portions of CRBRP encompassed by the calculational model.

Using the 42 group flux values, the Ni-59 inventory at point i becomes:

42 (2) Bj = T Aj hj+gj oAg g

! The value of At is that of Ni-58 occurring in the material at point i.

Using values of the Ni-58 capture cross section, oAg, for each group, the values of Bj were determined. These values were multiplied by the Ni-59 decay constant, Aj, to yield the Ni-59. decay rate as follows:

(3) Sj = Aj Bi 1

a _ _ _ - - - _ - _ _ _ _ _ _ _

. 1

, . l where: Sj = Ni-59 activity , disintegrations /second, at point i '

4 Ai = (in 2.0)/8.0 x 10 years .= 2.747 .x 10-13 sec -I '

Ni-59 Gama-Ray and X-Ray Source The Ni-59 gama-ray source can be calculated by considering the frequency and spectrum of emission. Ni-59 decays by radiative K-electron capture, emitting a spectrum of gama radiation with energies bet.een 0.0 anj 1.062 MeV. In addition, an 8.3 kev characteristic X-ray from daughter Co-59 de-excitation is emitted. In detennining the fre-quency, it should be noted that each K-capture in Ni-59 does not result in gama emission; rather, the total number of gamas emitted per K-capture is: _

a f Eo ) 2 I4) NT = 12w ~

where: N = total number of gammas emitted per Ni-59 decay

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a = fine structure constant = 7.2972 x 10 E = electron rest mass energy = 0.511 MeV mc e

Eo = Ni-59 gama endpoint energy = 1.062 MeV Solving equation (4) results in the value of NT as follows:

(5) NTY = 8.36 x 10 (y/ disintegration)

I The energy spectrum of emitted gamas in Ni-59 can be determined in the following manner.

For a gama emitted with an energy Ey, where 0 SEy1Eo, the number of gamas emitted per unit energy is:

" 2 (6) Ny (Ey) = C (Ey) [1 - o[E3E y w[m 2c } 2

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where:

C (E) =r constant Integrating this equation over all E yyields N , as previously derived.

To find the number of gamas emitted in an energy interval. bounded by Ej and E2 , where 011121 E E E O, the above equ: tion may be integrated over Ey in the range El to E2 .

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The ratio of the two integrals, X y (E), E2 ), will be:

2 3 E -E E -E Ef-E #

(7) X y (Ej, E2 ) =6.0' 2 -8.0' 3 +3.0 4 E E E 0 0 O y's emitted with E11Ey12 E (8) X 7 (Ej E2 ) "

y's emitted with 0 <E gEo ,

Based on X 7 (Ej. E 2), the Ni-59 gama source with energy between El and E2 at a point (i) can be calculated as:

(9) Sy j (E1 , E2)

  • Si N X y (E1 , E2 )

Resulting values of S y j (E 1 , E2 ) indicate that the highest radiation field will exist on the inside surface of the fixed radial shield (FRS) at core midplane. The source of 8.3 kev X-rays at this point will be the corre-sponding value of Si , since an 8.3 kev X-ray is emitted for each Ni-59 decay.

Radiation Transport and Dose Rates The maximum Ni-59 gamma source level was used as a distributed source .

in a one-dimensional discrete ordinates transport solution (i.e., the ANISN-W computer program) to calculate the gamma dose at the surface of the FRS. A 46-group energy structure was used in the multigroup calculation where each group's energy boundaries, E l and E2 , was used in detemining the gama source, Sy j (Ej , E2 ). The FRS was modeled as a infinite cylinder with an inside diameter and thickness equal to the CRBRP FRS design. A total of 100 or 200 spatial mesh were used in the calculation to assure that the gama transport was correctly calculated. ,

. The dose rate due to the 8.3 kev X-ray of Ni-59 was calculated for an infinite slab using the maximum activation and the following equation:

(10) D=

2 W ea where: D = dose rate (mrem /hr) mrem /hr K = dose conversion factor of 0.44 2

E = X-ray energy of 0.0083 MeV/ disintegration Sv

= volumetric source (disintegrations 3

( cm -sec )

yea = iron energy absorption cross section = 1485 cm-I The values ofu ea and X were obtained by interpolation of energy absorp-tion cross sections for iron and the constituents of human tissue.

Results Maximum dose rates from Ni-59 at the FRS inner surface are 5.1 mrem / hour from K-electron capture gama emission, and 3.2 mrem / hour from X-ray emission.

Dose rates at the inside surface of the SS304 reactor vessel (RV) midplane based on an infinite cylinder geometry are 0.23 and 0.17 mrem / hour for' gamma and.X-Rays, respectively.

Dose Rate from Nb-94

- Dose rates from the Nb-94 activity in the FRS and RV were detemined in a similar manner to that discussed in the previous section for Ni-59.

The maximum activity level in the FRS or RV was evaluated using the 42 group neutron fluxes at the inner surface'of the FRS or RV and the r.ultigroup cross sections for the production of Nb-94 due to neutron capture. The target 1

! nuclei density in the SS316 material was based on a conservative estimate of i

Nb content of 0.05 weight percent or a target nuclei density of 0.0000259 3 4 atoms /cm . Nb-94 decays with a half-life of 2.03x10 years by beta emission to Mo-94. The Mo-94 decay yields two gama ray emissions of 0.703 and 0.871 MeV. Thus, each Nb-94 decay yields two energetic gamma rays which dominate l the dose rate from Nb-94. The dose rates from Nb-94 activity in the FRS and RV were calculated using the same techniques described in the previous section of Ni-59. At the inner surface of the FRS, the dose rate due to Nb-94 activ-i ity is 2.2 Rem / hour. The dose rate at the inner surface of the RV is calcu-lated to be 66.2 mrem / hour.

Dose Rate from Co-60 Dose rates from Co-60 activity were detemined in a manner similar to that of Ni S9 The total inventory was evaluated at the saturation imel of the isotope using 42 group neutron flux values and cross sections for l

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the prinicpal production reactions, Co-59 (n,y) Co-60 and Ni-69 (n, p) .

Co-60. The frequency and spectrum of decay used were discrete energy gammas,1.17 and 1.33 MeV, emitted during each Co-60 decay. As in the case for Ni-59, th.e FRS inside surface at core midplane produced the 5

maximum radiation field, yielding a dose rate of 1.3 x 10 Rem / hour.

The dose rate at the RV inside surface at midplane height was calculated 3

to be 3.95 x 10 Rem / hour.

Total Dose Rate i The total dose rates at the inner surface of the FRS and RV are shown in Figures 2 and 3, respectively, as a function of time after shut- _

down. In the time period of 2.0 years after shutdown and beyond, Ni-5,9, Nb-94, and Co-60 will dominate the radiation environment adjacent to the CRBRP components. The.FRS values shown in Figure 3 illustrate that the Co-60 activity will dominate out to 100 years after which the Nb-94 activity will be the dominant contributor.

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f Figure 1. CRBRP Reactor System Schematic - Permanent Components (Hashed Regions) Considered in Analysis of Ni-59, Nb-94, and Co-60 Dose Rates Figure 2. Time Dependence of Dose Rate at Inner Surface of CRBRP Fixed Radial Shield at Core Midplane Figure 3. Time Dependence of Dose Rate at Inner Surface of CRBRP Reactor Vessel at Core Midplane e

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Considered in Analysis of Ni-59. Nb-94, and Co-60 Dose Rates 7434-1

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10 l l I g g.1 100 150 200 O 50 TIME AFTER SHUTDOWN, YEARS Figure 3. Time Dependence of Dose Rate at inner Surface of CRBRP Reactor Vessel at Core Midplane 7434-3 l -- -- - - - - - - . _ - _ _ _ . . , _ , _ _ . _ _ _ _ _ _ _ _ _ ,_ _ _ _ _ _

n . . ~ .m . . . o CRBRP NEUTRON-ACTIVATED COMPONENTS / STRUCTURES

1. Reactor Internals: .. ,

Activity >70 uti/qm Upper Internal Structure Fuel Transfer & Storage Assembly Reactor Vessel Thermal Liner Fixed Shielding .

Core Fonner Structure Bypass Flow Module Core Support Structure Lower Inlet Modules Control Rod Driveline Shroud Tubes Horizontal Baffle Assembly -

Removable Radial Shie,1,d N. Reactor

Enclosure:

Activity >70 vCi/gm

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Reactor Vessel (20' Section)

Reactor Guard Vessel Activity 1-70 uti/gm ,

Reactor Cavity Radiological Shield Reactor Vessel (40' Section)

Activity <1 uCi/gm Closure Head Shield & Seismic Support

3. Reactor Cavity Wall:

htivity1-70uCi/gm Cavity Wall (Inner 2.5')

Cavity Liner Support Ledge (Steel)

Activity <1 uCi/gm Cavity Wall (<2.5 ft. from Inner Surface)

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4. Reactor Cavity Piping:

- Activity 1-70 pCi/gm Inlet Piping Outlet Piping

5. Ancillary Equipment (Reactor Cavity):

Activity 1-70 uC1/qm f

Trace Heating System

. Flux Monitoring System.

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STATEMENT OF QUALIFICATIONS Lee E. Strawbridge Manager, Nuclear Safety and Licensing Westinghouse Advanced Reactors Division Madison, Pennsylvania 15663 I received a Bachelor of Science degree in Electrical Engineering from Pennsylvania State University in 1958 and a Master of Science degree in Nuclear Engineering from Massachusetts Institute of Technology in 1959.

Following graduation from M.I.T., I joined Westinghouse Electric Corporation in 1959 as a Scientist in the Atomic Power Division and was in the

~

position of Senior Scientist from 1962 to 1964. In these positions, I performed nuclear design analyses for Pressurized Water Reactors and a wide range of advanced reactor concepts including thermal, epi-thermal and fast reactors.

From 1964 to 1966, I was Manager of Nuclear Development with responsi-bility for developing analytic techniques and applying them to the nuclear analysis of Pressurized Water Reactors and advanced reactors concepts. This included con-ceptual nuclear design analyses of a modular 1000 MWe LMFBR.

Upon formation of the Westinghouse Advancdd Reactors Division in 1966, I was named Manager of Nuclear Development, with responsibility for all nuclear design analyses within the division. This consisted totally of work on sodium cooled fast reactors. I continued in this position until 1968.

From 1968 to 1971, I was Manager of FFTF Nuclear Design, with responsi-bility for the nuclear analysis and nuclear design of the Fast Flux Test Facility.

From 1971 to 1974 I was Manager of LMFBR Safety and Licensing, with responsibility for the safety and licensing activities associated with the LMFBR Project Definition Phase, which fonned the basis for the Westinghouse proposal '

for CRBRP. The conceptual design activities for CRBRP were completed during this period and the initial specification of structural margin beyond the design base loads,was made.

From 1974 to 1976, I was Manager of Safety Analysis with responsibility for directing many of the safety analyses reported in the CRBRP Environmental Report and the Preliminary Safety Analysis Report. In addition, safety analyses were performed and substantial input was provided to the FFTF Final Safety Analysis Report. -

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- - From 1976 to 1980, I was Manager of CRBRP Margin Analysis and Design, with responsibility for directing the analyses of hypothetical core disruptive accidents. This included the specification of structural and thermal margin requirements to mitigate the consequences of accidents beyond the design base and the preparation and submittal to NRC of the document CRBRP-3, " Hypothetical Core Disruptive Accident Considerations in CRBRP."

Since 1980, I have been in my current position of Manager, Nuclear Safety and Licensing with responsibility for directing safety analyses and licensing activities performed at the Waltz Mill site for CRBRP and other nuclear projects.

I am a Professional Engineer, registered in the Commonwealth of Pennsylvania since 1967.

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BIMRAM , l JOHN R. LONGENECKER i

ACTING DIRECTOR, OFFICE OF THE CLINCH RIVER BREEDER REACTOR PLANT PROJECT i 0FFICE OF BREEDER REACTOR PROGRAM 5 U.S. DEPAR1 MENT OF' ENERGY- .

John R. Longenecker is Acting Director of the Office of the Clinch River Breeder Reactor Plant (CRBRP) Project in the Department of Energy (DOE).

Included within his msponsibility is the licensing and program management of the CRBRP. and dimetion of the conceptual design of the Liquid Metal Fast Breeder Reactor (LMFBR) large developmental plant.

Prior to this assigrrnent, Mr. Longenecker served as Director Division of Plant Developraent; Chief. Conceptual Design Study Division of Reactor Research and Technology (RRT); Technical Assistant to the Program Director, Nuclear Energy of DOE; and in various capacities in the Energy Research afid Development Administration's (ERDA) Division of Reactor Research and Development including Special' Assistant to the Director. Acting Assistant Project Director for Procurement for the CRBRP. Acting Chief of CRBRP Mechanical Components Bronch and Reactor Engineer for various LMFBR pro.iects. He joined the Atomic Energy Coun1ssion in 1973 a'nd served there in the Division of.Reactbr Development and Technology prior to a

the formation of ERDA in 1975, and DOE in 1978.

Prior to entering sovernment service, Mr. Longenecker m empicycd by the Ford Motor Company as a research engineer and by the firm of John Robinson s '

and Associates as a structural engineer.

  • Mr. Longenecker received both Bachelor of Science and Master of Science degrees in Solid State Mechanics fra the Pennsylvania State University.

E Mr. Longenecker was born in Port Royal, Pennsylvania or July 27,1949.

and resides in Monrovia. Maryland. .

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 os 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 35 and 48 in the Nineteenth Set.
2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

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SUBSCRIBED and SWORN to before me ythe of [

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( #1W Notary Public

UNITED STATES OF AERICA NUCLEAR REGULATORY COMMISSION In the matter of )

UNITED STATES DEPARTMENT OF ENERGY PROJECT MANAGEMENT CORPORATION Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

(Clinch River Breeder Reacto,r Plant)

AFFIDAVIT OF Richard Disney, being duly sworn, deposes and says as follows:

1. That he is employed by Westinghouse Electric Corporation, Advanced Reactors Division, P.O. Box 158, Madison, Pennsylvania,15663 as Manager of Shielding Analysis.
2. That he is duly authorized to answer the Interrogatory Number VI,1, and 2 in NRDC's 18th set of Interrogatories.
3. That the above-mentioned and attached updated answers are true and correct to the best of his knowledge and belief.

k (Sign ture) l Subscribed and Sworn to before me thisMdday o 982.

O hotary PubN MARY G. HAYDEN. NOIARY PUBUCA ~

SEwlCKLEY TWP., WESTMORELAND COU@

MY COMMIS$10N EJPIRES FEB. 15.1984 Member,Pennytvania Assoda*mn ygsanes, My Comission expires

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A1 FISAVIT OF NEli. 'n'. BROWh; Ne i l 'n'. Hsuwn. being duly cunrn, depot.uu anc says as follevrt:

1. fhat he 1*.  ::ipinyud by Lhe Gcncral Flectric Cn:spany an Specia]ist, CR3Ri' !.icer, sing , Advi:nrert RencLur Systwas Uc.inrtrent . '110 DeCulgne Drive. Stai::yva l e , C.111forpio 9/*U Mh .
2. ;liat 1.c in duly atif h:>rixuci Lu a::wwer jntevrny,nt ory 16 in Lhe -1;h LuunLh nwL of 13t(!"n!*:t t e ri s*ft to thu App 11 Cant.
3. That ! hst nbevu-u.entioied add n*tnrhed nutswur it ;rve and enfrent t c t r'h b e *41 01 hin kus*wluegd afd belit'f.

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NUCLEAR REGULATORY COMMISSION

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In the Matter of '

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UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION )

.e No. 50 537 TENNESSEE VALLEY AUTii0RITY

)

(Clinch River Breeder Reactor Plant) )

)

)

)

AFFIDAVIT of Peter J. Gross, being duly sworn, deposes and says as follows:

1. That he is employed as Assistant Director Public Safety Division. CRBRP Project Office. Box V, Oak Ridge, Tennessee 37830. .
2. That the supplemental response to req 0est for identification of witnesses is true and correct to the best of his knowledge and belief.

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SUBSCRIBFD and SWORN to before me this day of August. 1982 ff f (Notaryfublic 4 .. X 't'U U 6 La >

My Commission expires , 19 .

.y Commission Expires Aprt) 28, M 001,9-939 S1:1 390I8 >lWO duSB3 IWD 23 :6T 090/W80 1

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I om $Gkgyfg \h NB UNITED STATES OF AMERICA F rem . 14 . er y , Pi pe p NUCLEAR REGULATORY CbMMISSION (RSAP In the Matter of ) .

DEPARTMENT OF ENERGY )

DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY )

AFFIDAVIT OF George H. Clare being duly sworn, deposes and says as follows:

1. That he is employed by Westinabouse Electr.i.C.. car _porat_ign .__

ao Manageg Licensing, Clinch River Breeder Reactor Project, Westinghouse Advanced Raactors Division Post Office. Box W Oak Ridge. l'ennessee 37830

_ ---=-

2. That he $s duIy authorized to answer the Interrogatories numbered _27 (revised response) in NRDC's 19t,h. set of Interrogatories.
3. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

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S M Ti SUBSCR!EED nr.d EWORM to bef orc ~ tr.c thi N day of

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th]/12 l4(__ , 1982.

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Notary Public //

My com.insion expires '2',"D- -

0019-9E9 Sid 390I8 MUO dN883 1ND GE:61 090/W80 6

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

UNITED STA1ES DEPARTMEhT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION Docket No. 50_S37

)

)

TENNESSEE VALLEY AUTHORITY )

)

)

(Clinch River Breeder Reactor Plant) )

)

._)

AFFIDAVIT of H. Wayne Hibbitts, being duly sworn, deposes and

  • says as follows:
1. That he is employed as Chief. Safety and Environmental Uranch.

Public Safety Division, CRBRP Project. Box U, Oak Ridge, Tennessee 37830.

2. That he is duly authori;ted to answer IV. Contention 5, Interrogatory number 1 in NRDC's 18th Set of Interrogatories. -
3. That the above-mentioned and attached answers are true and I

correct to the best of his knowledge and belief.

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_/N (SIGNATWE) s ~ '

SUBSCRIBED 'and SWORN to before me this day of August 1982.

_. <-& k Y N 'ota rf' Public)

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l l My Commission expires , 19 .

l l My Commission Expires April N. ?EF 0019-929 Sid 3D0I8 NWO dB883 1ND 95:6T 090/H80 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

)

l In the Matter of UNITED STATES DEPARTMENT OF ENERGY >

Docket No. 50-537

)

PROJECT MANAGEMENT CORPORATION )

)

TENNESSEE VALLEY AUTHORITY -

)

(Clinch River Breeder Reactor Plant)

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

      • Marshall E. Miller, Esquire -

l Chairman I

Atomic Safety & Licensing Board r

U. S. Nuclear Regulatory Commission

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Washington, D. C. 20545

      • Ruthanne G. Miller, Esq.

- Atomic Safety and 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 l

Bodega Bay, California 94923

  • ***Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545
  • Daniel Swanson, Esquire
  • Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission 20545 (2 copies)

Washington, D. C.

  • 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 '

U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (3 copies) -

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)

Ellyn R. Weiss, Esquire Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006 i

I

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Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esq.

Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq.

Warren E. Bergholz, Jr., Esq.

U. S. Department of Energy 1000 Independence Ave., S. W. _

Room 6-B-256, Forrestal Building Washington, D. C. 20585 (2 copies)

- **Eldon V. C. Greenberg Tuttle & Taylor 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

(

eorge/L. Edgar C' Attorney for Proj ect Management Corporation DATED: August 6, 1982 1

  • / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
    • f Denotes hand delivery to indicated address.
      • / Denotes hand delivery to 4350 East-West Highway, Bethesda, Md.