ML20062E412

Supplemental Answers to NRDC & Sierra Club twenty-sixth Set of Interrogatories.Certificate of Svc Encl

ML20062E412
Person / Time
Site:	Clinch River
Issue date:	08/05/1982
From:	Bradley Jones NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	National Resources Defense Council, Sierra Club
Shared Package
ML20062E380	List: ML20062E379 ML20062E412
References
NUDOCS 8208100098
Download: ML20062E412 (33)

Text

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c' 08/05/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)

NRC STAFF'S SUPPLEMENTAL ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TWENTY-SIXTH SET OF INTERROGATORIES TO STAFF On July 27, 1982, the NRC Staff (" Staff") filed "NRC Staff's Answers to Natural Resources Defense Council, Inc. and the Sierra Club Twenty-Sixth Set of Interrogator'ies to Staff" (" Answers"). Those interrogatories relate to the Site Suitability Report in the Matter of the Clinch River Breeder Reactor Plant (Revision to March 4, 1977 Report) NUREG-0786, (June 1982).

In its Answers, the Staff noted that certain responses required information or analysis which could not be furnished in time for that submittal and that the Staff would provide those answers on or before August 6,1982.

In addition, attached to the Staff's Answers were the affidavits of three sponsors of those Answers; to the extent not provided therewith, the Staff indicated that further signed and notarized affidavits would be provided as soon as possible.

In its Answers, the Staff objected to answering certain inter- -[ 4 rogatories. The Staff has now had an opportunity to confer with the -

4 8208100098 820805 PDR ADOCK 05000537 '

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Intervenors, and have agreed to provide answers to all of the interroga-tories which had been previously objected to, except as to Interroga-tories IV 3-7,12, and 13; those remaining Interrogatories have been withdrawn by the Intervenors.

At this time the Staff completes its response to the Intervenors' 26th Set of Interrogatories. Attached hereto are the Staff's answers to those Interrogatories which were not provided in the Staff's Answers of July 27, 1982, as well as the affidavits of the other Staff employees who participated in preparing the Staff's Answers.

On March 4,1982, the parties in this proceeding developed a Protocol for Discovery, pursuant to which NRDC and the Sierra Club have requested that answers to interrogatories be provided in six parts, as follows:

(a) Provide the direct answer to the question.

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

(c) Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (b). In lieu thereof, at Staff's option, a copy of each such document and study may be attached to the answer.

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

(e) Explain whether Staff is presently engaged in or intends to engage ia ar.y further, ongoing research program which may

? affect Staff ts answer. This answer need be provided only in cases where the Staff intends to rely upon ongoing research not included in Section 1.5 of the PSAR'at the LWA or donstruction permit hearing on the CRBR. Failure to provide

• [.

such an answer means that Staf f does not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.

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(f) Identify the expert (s), if any, which Staff intends to have testify on the subject matter questioned, and state the qualifications of each such expert. This answer may be provided for each separate question or for a group of related questions. This answer need not be provided until Staff has in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.

For all responses to interrogatories herein, the following are the Staff's answers to the requests set forth above:

(a) Direct answers are provided for each question.

(b) All documents and studies, and the particular parts thereof, relied upon by the Staff now or in the past which serve as the basis for the answer are identified in the answer to the question, unless otherwise noted.

(c) There are no principal documents and studies specifically exanined but not cited in (b), unless otherwise noted.

(d) The name, title and affiliation of the primary Staff employee (s) or consultant (s) who provided the answer to the question are set forth in the attached affidavits, unless otherwise indicated herein.

(e) The Staff is not presently engaged in nor does it intend to engage in any further, on-going research program which may affect the Staff's answer, unless otherwise noted.

(f) At this time, the Staff has not determined who will testify on the subject matter questioned. Reasonable notice will be given to all parties after the Staff has made this deter-mination. At that time, a statement of professional qualifications will be provided for each witness.

Respectfully submitted, e .-

Bradley W. ones Counsel for NRC Staf Dated at Bethesda, Maryland this ifAday of August, 1982

NRC STAFF'S SUPPLEMENTAL ANSWERS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TWENTY-SIXTH SET OF INTERROGATORIES TO STAFF 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"). Thespecificpagenumber(s) referred to are indicated in parentheses at the beginning of each interrogatory.

I. General Questions .

Interrogatory 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 1982 SSR.

Response

Bar on page IV-6 Pearring IV-7 Pearring II. Sectwn I Interrogatory 3 Intervenors would like an explanation of which aspects or parameters of the present CRBR design Staff currently believes are adequate for purposes of site suitability; which aspects or paramsters require more Staff review before their adequacy can be determined; and which aspects or parameters are not adequate as '[

preseirtly designed. Please identify and describe each aspect or parameter of the present CRBR design which Staff currently believes:

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2 d) is not adequate for purposes of determining site suitability as presently designed, but which may be redesigned adequately, given the current state of technology.

Response _

The Staff finds the currently proposed design adequate for the purposes of determining site suitability. This question has been ,

addressed in the updated answer to Interrogatory Set 19, question 36.

There has been no new information which would change that response.

III. Section 11 Interrogatory 6 (11-2) Explain the present basis for Staff'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 applices to the CRBR7 If so, why does Staff require only two redundant and diverse shutdown systems?

Response

For the protection of the public health and safety, the CRBRP will be subject to regulation by the f4RC just as other licensed nuclear power plants. The overall protection of the public health and safety depends on many things; the shutdown systems are only one important aspect of the plant, and their contribution to safety must be judged in relation to the whole plant. See also the oral deposition on f1RDC interrogatories dated April 8,1982, transcript date[May6,.1982,pages12through25. ..

IV. The following interrogatories are related to the dose calculations appearing in Table IV (111-11).

Interrogatory 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 and low population zone. Identify each and every assumption, including a) each model equation and b) each input parameter, together with the basis for the choice of each assumption (equation and input value). Provide the source of each equation and each input parameter cited (PSAR, ER, Regulatory Guide, etc., with the appropriate page numbers). If a computer code is utilized (e.g., CRAC or TRAC), provide a printout of the code and all input and output data, together with a detailed description of the input and output format, and any documentation of the computer model.

Response

The description of the data base and methodology utilized by the Staff to generate the atmospheric disperson parameters and doses listed in Table IV is provided on Page IV-1. A printout of the computer code utilized by the Staff to generate these values and all input and output material has been made available to Intervenors.

Interrogatory 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 dose consequence results? If so, please identify 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 well as the basis for their rejection.

Response

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With kegard to the atmospheric dispersion analyses performed by the

• Staff, the Staff knows of no data which will yield more conservative results than those calculated by the Staff. The model and probabi-

0 listic assessment performed for the 1977 SRR are more conservative than those utilized in the updated SSR. The justification for the use of this revised evaluation technique is set forth below in response to Interrogatory IV.14.

With regard to dose models, assumptions with such models may always be made that yield more (or less) conservative dose consequences.

Furthemore, it requires informed judgment based on sound engineering and scientific principals to select a suitable set of assumptions to produce reasonable dose consequence estimates. It is the Staff's judgment that this criteria has been met in modeling the DBA in the site suitability report.

Interrogatory 14 l

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

a) What is the source for these new values?

b) Identify and provide all docurents used by Staff in developing these values.

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

Response

14 (a)&(b) The methodology utilized by the Staff in determining the appropriate meteorological atmospheric dilution factors (X/Q) for use in determining the consequences of potential accidental releases was described in the staff response to Contention 5, Inter- '[

rogatory 1 of the 9th Set of the NRDC and Sierra Club

C Interrogatories and is described in detail in Regulatory Guide 1.145,

" Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Plants" (August 1979). As stated in Section IVA of the updated SSR, the highest of the directional 0.5% exceedance X/Q values was utilized by the Staff. The X/Q values utilized are tabulated in Table IV of the updated SSR.

t (c) The X/Q values as stated in Table IV, which are somewhat less conservative than those listed in the 1977 SSR, are largely due to the use of a differing probabilistic assessment and a differing treatment of plume meander between then and now.

In the 1977 analyses, a directionally dependent methodology was utilized to determine the X/Q value which was used to estimate the consequences of accidental releases normalized 95% X/Q value was calculated for each direction, using the following equation:

P=100-[5(0.0625)3 f

P= Percent value corresponding to the normalized 95% X/Q value f= Frequency of occurrence of wind in the sector being considered.

In the updated SSR, the 0.5% exceedance X/Q value of the total time in each directional sector was utilized.

In each case (1977 & 1982) the worst of the directional X/Q values i

appropriately determined (normalized 95% or .0.5%) was utilized in

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the Staff analyses.

• o In the 1977 analysis, a plume meander factor of 4 was utilized for stabilities E, F and G associated with wind speeds less than 1 m/sec.

In the 1982 analysis, varying plume meander factors based on stability and wind speed as delineated in Figure 3 of Regulatory Guide 1.145 were utilized.

The reasons for the differences in the 1977 and 1982 analyses are because the 1977 analysis was performed at the time the directionally dependent model now utilized was in its formative stage. Since the 1977 analysis was performed additional diffusion studies were performed and the results of all available low wind speed diffusion studies were examined. Also, the development of a consistent directionally dependent X/Q probability value was studied to arrive at the 0.5% value presently utilized. The bases for both of these evaluations are described in NUREG/CR2260, " Technical Basis for Regulatory Guide 1.145, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants," October 1981.

Interrogatory 15

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

Response

The data utilized by the Staff in its analyses was collected at the CRBR site during the period 2/17/77 to 2/16/78. However, all of the-data collected from 1973 through 1978 were examined and reviewed "[

by the Staff.

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Interrogatory 16 I

Have Applicants collected meteorological data during other periods of equal length (eg. ,1 year) that Staff believes would be adequate for purposes of calculating atmospheric dispersion parameters for the CRBR site?

Response

Our understanding is that meteorological data collection was initially begun on April 11, 1973. Data were collected at several different locations on-site with differing equipment through February 16, 1978.

Prior to early 1976 the meteorological measurements program either utilized instrumentation that did not meet Regulatory Guide 1.23 sensitivity requirements, had poor data recovery (less than 90%),

or required substitution and conversion of 75 foot wind data to the 33 foot level. The data from March,1976 through February,1977 were also analyzed utilizing the methodology described in Regulatory Guide 1.145. For this year of data the maximum 0.5% directional exceedance value was the most limiting X/Q value rather than the non-directional 5% value. The following table presents the results of this analysis along with the February 17, 1977 to February 18, 1977 results for comparison purposes:

3 X/Q sec/m 76-77 77-78 3

0-2 hours at exclusion area boundary 1.1 1.22 X 10-3 0-8 hours at LPZ 1.2 X X 10 10-4 1.2 X 10-4 8-24 hours at LPZ 8.5 X 10-5 8.4 X 10-5 24-96 hours at LPZ 4.1 X 10-5 3.9 X 10-5 96-720 hours at LPZ 1.5 X 10-5 1.4 X 10-5 It can be seen from the above table that the exclusion zone boundary ~[

X/Q values for the 1977-78 data period were slightly more conserva-

O tive than that for the 1976-77 data, with the longer time period X/Q values (8 through 624 hours0.00722 days <br />0.173 hours <br />0.00103 weeks <br />2.37432e-4 months <br />) virtually identical. Since the 1977-78 data were taken on the permanent tower upon which future data will be collected, and the data set collected during construction would be compared with data collected at the same tower location, it was decided to utilize the 1977-78 data in the Staff radioactivity release consequence analyses. The results listed in Table IV of the updated SSR reflect this period.

In sum, since the meteorological data collected prior to 1976 did not fully meet all of the Regulatory Guide 1.23 guidance criteria, the 1977-78 data were collected on the permanent tower upon which future data will be collected, and the exclusion boundary X/Q values were slightly more conservative than the 1976-77 results, it was decided to utilize the 1977-78 data for the Staff dose consequence analyses.

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

Response

One year of data, from either the March,1976 through February,1977' and/or the February 17, 1977 through February 16, 1978 period are adequate for purposes of calculating atmospheric dispersion para-meters for the CRBR site.  ;

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Interrogatory 18 Does Staff take the position that Staff or Applicants are free to choose the time interval (i.e. beginning and ending dates) which gives the smallest X/Q values, provided the length of the time interval and all other considerations meet Regulatory Guide 1.145 requirements? Explain in detail the basis for Staff's answer.

Response

No. As long as the meteorological data-meet the acceptance criteria provided in Regulatory 1.23, all of the data collected should be utilized in making the Regulatory Guide 1.145 analyses.

Interrogatory 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.

Response

The Staff believes that the X/Q values in Table IV are appropriately conservative for assessing the consequences of accidental releases.

See the response to Question 16 for the justification for this response.

Interrogatory 20 l

Why doesn't Staff require or utilize an analysis of the entire time interval during which adequate meteorological data is available for purposes of calculating X/Q values?

! Response The Staff does utilize all data collected over to the extent that data l

meets,. Regulatory Guide 1.23 acceptance criteria for its X/Q analyses. .-

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4 Interrogatory 21 Approximately how many years of site meteorological data does Staff believe one would need in order to have reasonable confidence that the derived atmosphere 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 Staff relies for its answer.

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

Response

The Staff has concluded generically that one full annual cycle of meteorological data, provided that this data has been compared with long term records and other data collected in the same general area, is adequate to represent long-term expected meteorological conditions at a particular site. For the CRBR site diffusion estimates for the CRBR site were compared with other similar estimates at other reactor sites in the same general area. (See Staff updated response to Contention 5, Interrogatory 5 of the 9th Set of the NRDC and Sierra Club Interrogatories). In addition, the Applicant presented long term wind records from Oak Ridge City and Knoxville which show comparability with both 1976-77 and 1977-78 data.

It should be noted that NUREG-0800 " Standard Review Plan for the Review of Safety Analysis Reports for the Review of Safety Analysis Reports for Nuclear Power Plants" provides the following require-ments-with regard to the collection of on-site meteorological data to meet Part 100 and Appendix I of Part 50: ~[

1. The onsite meteorological measurements programs should produce data which can be summarized to provide a description of the meteorological characteristics of the site and its vicinity for the purpose of making atmospheric dispersion estimates for both postulated accidental and expected routine airborne releases of effluents and for comparison with offsite sources to determine the appropriateness of climatological data used for design considerations. The criteria for an acceptable onsite meteorological measurements program are documented in the Regulatory Position, Section C, of Regulatory Guide 1.23 (Ref. 6).

2. The following additional criteria are used to judge the acceptability of meteorological data summaries for atmospheric dispersion estimates (Ref. 7).

a. For the Preliminary Safety Analysis Report (PSAR), at least one annual cycle of onsite meteorological data should be provided at docketing.

b. For the Final Safety Analysis Report (FSAR), at least two consecutive annual cycles, including the most recent one-year period, should be provided at docketing.

Meteorological data should be presented in the form of joint frequency distributions of wind speed and wind direction by atmospheric stability class in the format described in Regulatory Guide 1.23. A listing of each hour of the hourly-averaged parameters should be provided on magnetic tape in the format described in the Appendix to this Standard Review Plan section.

Evidence of how well these data represent long-term conditions at the site should be presented.

21a. Yes. The professional meteorologists on the Staff agree that the above requirements are sound technically and that the CRBR meteo$ologicaldatathatwasutilizedbytheStaffmeetstheabove ~[

requirements.

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Interrogatory 22 What model(s) were used by Staff to calculate the organ doses (in rems) per curie of activity inhaled and for external and [ sic]

exposures? Identify and provide all documents upon which Staff relies for its answer.

Interrogatory 36 How were the inhalation dose factors (rem /Ci Inhaled) calculated for a) thyroid; b) whole body; c) lung; d) bone surfaces?

Response to IV.22 and IV.36 For the significant nuclides in the pathways considered in the SSR the dose commitment factors (DCF) were computed using one of two models. For thyroid inhalation the DCF's in rems per curie were computed by the methodology described in a USAEC document TID 14844, Calculation of Distance Factors for Power and Test Reactor Sites.

Whole body immersion DCF's in rems per sec/ curie per cubic meter and other inhalation DCF's were computed with the model detailed in a USNRC document NUREG-0172, Age Specific Radiation Dose Commit-ment Factors for a One Year Chronic Intake. Whole body inhalation DCF's were not used.

Interrogatory 23 l What plutonium content did Staff assume would be used to fuel the i CRBR? e ."

a) Did Staff examine the effect on oxygen [ organ] dose l

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calculations of switching from fuel-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.

Response

Further response to Interrogatory IV-23 of the Twenty-sixth Set.

NRDC has explained that the interrogatory should have read

" organ dose" rather than " oxygen does". Staff considered the effect on organ dose calculations in selecting the plutonium composition to be used for the calculations. References were CRBRP-3, Vol.2, Rev.

O, pages 4-13 and 4-22; the CRBRP R, Section 5.7.1.4, page 5.7-22 (Amendment XIV); Final GESMO, NUREG-0002, Vol.2, pages I(A)-2 and 11-30; and data in CRP Publication 30, Part 1. No written numerical analysis was made, therefore we have no exact numerical comparison of the effect on dose calculations of using reactor grade fuel.

Interrogatory 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?

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

Response

See the Staff response to Question 14 Inter ogatory.33 .,.

What assumptions are made with regard to LPZ dose commitments beyond 30 days?

a) What is the basis for these assumptions?

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

c) What fraction of the total LPZ lung and bone 50-year dose commitments are due to release in the first 30 days, where total dose commitment implies integration of the release for a period much greater than 30 days (Je. ., until essentially all of the plutonium aerosol is released or otherwise unavailable because of fallout)?

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

Response

In the case of LWR's, the dose contribution beyond 30 days is negligible. However, in the case of CRBR, the doses were found to be significantly larger for a puff release at the end of 30 days (considered to be a worse case condition), than the doses calculated for the first 30 days. However, the doses would still be within the proposed deses guidelines at the CP stage (see table below).

0-30 Day Plus, CP Stage Dose Organ 0-30 Day Puff Release Guidelines Whole Body 0.34 0.47 20 Thyroid 6.8 11.6 150 Lung 0.37 1.58 37.5 Red Bone Marrow 2.11 9.06 37.5 Bone Surface 26.8 115.0 150 Liver 0.98 4.12 75

• Puff release from primary to Annulus Filtration System postu-lated for dose computational purposes (21% released to envi-ronment and 79% filtered and recirculated to annulus region).

! Interrogatory 34 i What assumptions are made with regard to dose commitments via l pathways involving exposure following ground contamination? Explain in detail the basis for Staff's answer.

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

Response

The Staff does not normally calculate the radition doses from ground deposition. The justification for this is:

(1) The Staff's judgment is that the dose consequences from immersion in the plume are significantly greater than dose consequences from ground deposition.

(2) In the event of deposition in a populated area, the population could be evacuated prior to the deposition resulting in significant dose consequences.

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

Response

The table showing the doses contribution by major isotopic contri-butor is as follows:

E.A.B. Dose LPZ Dose Major Isotopic  % Contri Organ' (0-2 hr) (0-30 Day Contributor bution Whole body 0.6 0.3 Noble Gases 95%

Thyroid 12 7 Halogens 100% ',

Lung ? 0.4 0.4 Plutonium 97%  ;-

. Red Bohe Marrow 24 2 Plutonium 99%

Bone Surface 31 27 Plutonium 100%

Liver 1. 1 Plutonium 96%

i

Interrogatory 38 Provide a table of the CRBRP heavy metal inventory (all U, Np, Pu, Am, Cm, and Cx [ sic] isotopes) in curies for E0EC conditions.

Respanse See PSAR Tables 15.A-2 and 15.A-3. j l

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V.Section III Interrogatory 1 (III-9, 10) 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 Staff's decision to use a mortality risk equivalent whole body dose rather than a morbidity risk equivalent 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 effects.

d) Explain fully the basis for Staff's decision not to utilize the recommendations by EPA in EPA 520/4-77-016,

" Proposed Guidance on Dose Limits for Persons Exposed to Transuranium Elemets 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 l in Section B of Regulatory Guides 1.3 and 1.4 by reducing the  !

lung and bone dose cuidelines by a factor of 10 for use at the l CP review stage (1977 SSR, p. III-16). In the 1982 SSR uncertainties regarding lung and bone (surface) doses. Isn't the effect of the new Staff methodology to reduce the lung and bone factor (i.e., the factor to account for uncertainties at gheCPstage)from10toapproximately2? -[ l

0 f) Explain fully the underlying basis for constructing a methodology that has the effect of reducing the factors of conservatism to account for these uncertainties.

g) In application of the "ICRP 26 methodology" doesn't Staff'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 Staff disagrees, explain fully the basis for such disagreement.

Response

(a) The guidelines for doses to the lung and bone surfaces were derived from the guidelines for the thyroid (300 rems) using the mortality risk weighting factors contained in ICRP Publication 26. The approach in developing the dose guidelines for individual organs for CRBR was simply an extension of the

" critical organ" method which is implicit in 10 C.F.R. Part 100. The Staff selected the set of stochastic weighting factors recommended in ICRP Publication 26. The Staff did not explicitly reject the weighting factors proposed by EPA (see EPA 520/4-81-003, p.10). However, the Staff notes that the weighting factors proposed by EPA have been issued for public comment, and as such are not final.

(b) The Staff used the mortality risk equivalent whole body dose, rather than a morbidity risk equivalent whole body dose, because mortality risk weighting factors can be taken directly from authoritative reports, such as ICRP-26. In contrast, sorbidity risk weighting factors are not directly available in

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authoritative reports, such as ICRP-26, BEIR I and BEIR III, and must be derived by the Staff.

(c) As in 10 C.F.R. Part 100, the dose guidelines as set forth in these siting criteria are not intended to imply that the numbers constitute acceptable limits for emergency doses to the public under accident conditions. Rather, the guidelines have been set forth as reference values which can be used in evaluating reactor sites with respect to potential reactor accidents of exceeding low probability of occurrence and low risk of public exposure.

(d) The Staff's dose guidelines in NUREG-0786 (p.III-9) are not intended to imply that these numbers constitute acceptable limits for emergency doses to the public under accident conditions. Rather, the guidelines have been set forth as reference values which can be used in evaluating reactor sites with respect to potential reactor accidents of exceeding low probability of occurrence and low risk of public exposure.

In contrast, EPA states that the purpose of its proposed guidance on transuranics in the environment is "to establish maximum dose rates for persons in the general population who might receive radiation exposure to transuranium elements in the environment, which considers all possible pathways to humans and which the Agency judges to be protective of the

public health." (EPA 520/A-77-016, p.14). Thus, the Staff does not utilize the EPA guidelines because the purpose for the Staff's dose guidelines is quite different than the purpose for the referenced recommendations by EPA.

(e-9) In the 1977 SSR, the Staff used a factor of 10 to reduce the dose guidelines for the lung and bone dose at the CP stage. The factor 10 was the product of two factors:

(1) a factor of about 2 to take into account uncertanties noted in Section 3 of Regulagory Guides 1.3 and 1.4 (as is done for LWR's).

(2) A conservative factor of 5 to take into account uncertainties in dose and health effect models.

In the 1982 SSR, the Staff has continued to use a factor of about 2 to take into account uncertainties noted in Section B of Regulatory Guides 1.3 and 1.4 Since the publication of the 1977 SSR, there have been a number of reports by authoritive bodies that have dis-cussed doses and/or health effects from alpha emitting particles. These reports include:

(1) Recommendation of the International Commission e .*

on Radiological Protection (ICRP-26).

(2) Limit for Intake of Radionuclide by Workers (ICRP-30).

(3) The National Academy of Sciences BEIR III Report.

Based on the Staff's review of those reports, as well as several reports published shortly before the 1977 SSR ,

the Staff has concluded that the factor of 5 is no longer needed to take into account uncertainties in dose and health effects models.

In addition, the requirement that the mortality risk (3 factor for CRBR be no greater than that for an LWR (e.g.

whole body equivalent dose fo 34 rem at OL stage and 24.5 rem at CP stage) summed over all critical organs provides an additional margin of conservatism in modeling the doses for CRBR.

• National Academy of Sciences " Health Effects of Alpha-Emitting Particles in the Respiratory Tract" (EPA 520/4-76-013); and NCRP Report No. 46,

" Alpha-Emitting Particles in Lungs".

Interrogatory 3 (IIIs40) Explain fully the basis for Staff's statement that ORGDP, -f ORNL,'and Y-12 can be effectively evacuated without undue risk to national or energy security?

Response

Intervenor clarified this question per telecon on August 3,1982.

Intervenor stated that their question refers to the last paragraph on page 111-10. This paragraph points out that FEMA reviews the state and local plans. The Staff concludes that an effectively coordinated site state and local radiological emergency response plan can be achieved for the Clinch River site. This paragraph does not refer to national or energy security nor is is intended to imply any conclusion as to national security and energy security.

However, see response to V.5 26th set for Staff response on national I

security.  !

Interrogatory 5 (III-10) How long could the Y-12 facility remain evacuated without l adversely affecting national security?

Response

The discussion on page III-10 of the SSR is not intended to address any conclusions as to the effects of evacuation of the Y-12 facility on national security. The Staff in its analyses does not ascertain a specific period of time for evacuation after which national security will be adversely affected. In analyzing the effect of CRBR releases on Y-12 the Staff relies on the DOE for determinations as to whether national security will be affected as a result of evacuation resulting from a given accidental release. Therefore, the 9taff does not have any specific information as to the point at  ;

which evacuation would begin to adversely affect national security.

See also Staff response .to a similar question in Staff Answers to 25th set Set of Interrogatories, Interrogatory 59(4), and Applicant Response to 18th Set of Interrogatories, Interrogatory IV.I.

e 8

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO!!

BEFORE THE AT0t11C SAFETY AND LICENSING BOARD In the Matter of UtlITED STATES DEPARTMEtlT OF ENERGY Docket No. 50-537 PROJECT MAf! AGE!4ENT CORPORATION TElitiESSEE VALLEY AUTH0hlTY )

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF RICHARD M. STARK I, Richard M. Stark, being duly sworn, state as follows:

1. I ara employed by the U.S. Nuclear Regulatory Convaission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2. I am auly authorized to participate in answering #1, #2, and #3 of the General Questions, III.3d and III.6 of the 26th Set of Interrogatories filed on July 13, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

1 Of ,r1 Richard it. (Stark

(

l Subscribed and sworn to before me

this 'd ' day of August, 1982. ,,

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Notary Public My Commission expires: h .

l

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AfiD LICENSING BOARD In the Matter of Uli1TED STATES DEPARThENT OF EtlERGY ) Docket No. 50-537 PROJECT MANAGEMEllT CORPORATION )

TEN:ESSEE VALLEY AUTHORITY (ClinchRiverBreederReactorPlant) )

AFFIDAVIT OF RICHARD BECKER I, Richard Becker, being duly sworn, state as follows:

1. I am employed by the U.S. Nuclear Regulatory Conmission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

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2, I am duly authorized to participate in answering the 26th Set of Interrogatories, Interrogatories 11.2-5, III.1-13 and 17; filed on July 13,1982 and I hereby certify that the answers given are true l

to the best of my knowledge.

L&_

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I ,

Richard Beckbr

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Schscribed?and sworn to before me this .26d' day of July, 1982.

69tpfb8 M r Notary Public My Connission Expires:

hu I, R65' C

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF LARRY W. BELL I, Larry W. Bell, being duly sworn, state as follows:

1. I am employed by the U.S. Nuclear Regulatory Commission as a Nuclear Engineer with the Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2. I am duly authorized to particioate in answerino Interroaatnries IV.1, 2, 33, 34 and 37, and V.1 of the 26th Set of Interrogatories filed on July 13, 1982, and I hereby certify that the answers given are true to the best of my knowledge.

Larry W. Bell Subscribed and sworn to before me this day of August, 1982.

Notary Public ,.

My Commissioh expires: . .

3-UNITED STATES OF AMERICA HUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION ) ,

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) .) .

AFFIDAVIT OF MICHAEL E.: WANGLER I, Michael E. Wangler, being duly sworn, state as follows:

1. I am employed by the U.S. Nuclear Regulatory Commission as a Health Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2. I am duly authorized to participate in answering. Interrogatories, IV.22 and IV.36 of the 26th Set filed on July la,-1982, and I hereby certify that the aswers given are true to the best of my knowledge. /

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Michael E. Wangler Subscribed and sworn to before me this day of A.ugust, 1982. ..

. L Notary Public My Commission expires: .

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF IRWIN SPICKLER

'I, Irwin Spickler, being duly sworn, state as follaws:

1. I am employed by the U S. Nuclear Regulatory Comission as the Chief of Section C of the Accident Evaluation Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

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9' en

2. t am duly authorized to participate in answering Interrogatories e IV.1,2,14 through 21, and 32 of the 26th Set filed on July 13, 1982, and I hereby certify that the-answers given are true to the bestofmyknowledhe.

, )

i ,

Inlin Spickler Subscribed and sworn to before me this day of August, 1982.

Sotary Public i My Commission expires: .

e' UtilTED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10t:

BEFORE THE AT0fi!C SAFETY AND LICENSING BOARD In the flatter of UNITED STATES DEPAREEf!T OF ENERGY Docket No. 50-537 PROJECT MAfiAGEMENT CORPORATION

. TENT.ESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plar.t) )

AFFIDAVIT OF PAUL H. LEECH I, Paul H. Leech, being duly sworn, state as follows:

1. I am employed by the' U.S. Nuclear Regulatory Comission as a Project Manager, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2. I am duly authorized to participate in answering Interrogatories V.3 End V.5 of the 26th Set filed on July 13, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

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('\)ex d t r)s_

Paul H. Leech Subscribed and sworn to before me this - day of August, 1982.

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i.-

iioTary Public ',

• ~

F.y Comission expires: .t. .

I

D UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tVIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF EDWARD F. BRANAGAN, JR.

I, Edward F. Branagan, Jr. , being duly sworn, state as follows:

1. I am employed by the U.S. Nuclear Regulatory Commission as a Radiological Physicist, Radiological Assessment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation.

2. I am duly authorized to participate in answering Interrogatory V.1 of the 26th Set filed on July 13, 1982 and I hereby certify that the answers given are true to the best of my knowledge.

1 Edward F. Branagan, Jr.

Subscribed and sworn to before me this day of August, 1982.

e -l Notary Pubic My Commission expires: .

I

__m._ . _ _ _

9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UtilTED STATES DEPARTMENT OF ENERGY ) Docket No. 50-537 PROJECT MANAGEf TENT CORPORATION )

TEritiESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

AFFIDAVIT OF JERRY J. SWIFT I, Jerry J. Swift, being duly sworn, state as follows:

1. I am employed by the U.S. Nuclear Regulatory Comission as a Reactor Engineer, Clinch River Breeder Reactor Program Office, Office of Nuclear Reactor Regulation.

2. I am duly authorized to participate in answering Interrogatory IV.38 of the 26th Set filed on July 13, 1982, and I hereby certify that the answers given are true to the best of my knowledge.

Jerry J. Swif t Subscribed and sworn to before me this day of August, 1982.

Notary Public , , , ,

My Comissi6n expires: