ML20069L066

Second Set of CP Interrogatories & Request to Produce. Certificate of Svc Encl

ML20069L066
Person / Time
Site:	Clinch River
Issue date:	04/26/1983
From:	Scherr S National Resources Defense Council, Sierra Club
To:	JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
Shared Package
ML20069L064	List: ML20069L061 ML20069L066
References
NUDOCS 8304280022
Download: ML20069L066 (9)

Text

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9pWP April 29) 19,816 P4:27

,' . f UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

)

In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

PROJECF MANAGEMENT CORPORATION ) Docket No. 50-537 TENNESSEE VALLEY AUTHORITY )

)

-(Clinch River Breeder Reactor Plant) )

i )

)

NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB'S SECOND SET OF CONSTRUCTION PERMIT INTERROGATORIES l AND REQUEST TO PRODUCE TO APPLICANTS Pursuant to 10 CFR $ 2.740b, and in accordance with the Board's Construction Permit Scheduling Order of March 29, 1983, Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, submit the following interrogatories, to be answered f ully, in writing and under oath, by one or more of ficers or employees of Applicants who has personal knowledge thereof or is

!- the closest to having personal knowledge thereof. If the i

interrogatories are answered by more than one person, whether or 8304280022 930426 PDR ADDCK 05000537 G PDR

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not he or she verified the answers, and whether or not he or she '

is an officer or employee of Applicants, such person's name and title should be set forth together with an identification of which interrogatories he or she is responsible for.

Unless otherwise indicated, each question is addressed to all Applicants. In each question to all Applicants, each of the multiple Applicants is instructed to provide a separate answer.

However, when all Applicants are in agreement on.a response, only one uniform answer need be given.

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

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

1 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 Applicants, now or in the past, which serve as the basis for the answer. In lieu thereof, at Applicants' option, a copy of such document l

and study may be attached to the answer.

(c) Identify principal documents and studies, and the particular parts thereof, specifically examined by not L

!. cited in (b). In lieu thereof, at Applicants' option, a l

copy of each such document and study may be attached to the answer.

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

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

(f) Identify the expert (s), if any, which Applicants intend to have testify on the subject matter questioned, and state the qualifications of each such expert. This l

answer may be provided for each separate question or for a group of related questions. This answer need not be provided until Applicants have in f act identified the

expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.

i l- As used herein, " documents" include, but are not limited to papers, photographs, criteria, standards of review, recordings, memoranda, books , records, writings , letters, telegrams, l

mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interof fice, 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, axhibits, appraisals, work papers, reports , studies, 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 printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether formal or informal) of any of the foregoing, and also all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) f rom i

the original.

INTERROGATORIES

1. How many reactor-years of operation have been accumulated during the operating history of all U.S. Naval reactors?

2. How many ATWS events are known to have occurred among U.S.

Naval reactors during their history of operation. -

3. How many ATWS events are known to have occurred among AEC/ERDA/ DOE production reactors (the 5 at SRP and the 9 at Hanford) during their history of operation? Give the breakdown by reactor type.

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4. Explain the significance of the Salem ATWS events to Applicants' position regarding the probability of _ an ATWS event at CRBR.

5. Have Applicants calculated whole body and organ doses (see SER, p. A.5-10) , for the parameters given in SER Table A.5-1 (p.

A.5-9), except using 95% X/Qs instead of 50% X/Qs? If so, report all dose results for purposes of comparison wtih the results reported in Table A. 5-2.

6. If dose calculations were performed with some, but not all parameters in Table A.5-1 ( SE R, p. A.5-9) changed, e.g., if any-sensitivity results are available, ' report all dose results and the changes in input assumptions.

,7 . Identify all assumptions regarding plateout and fallout associated with the Applicants' dose calculations reported in SER

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Table A.5-2.

Respectfully submitted, i 1 l 4lMdd dw Bar ra A. inamore S. Jacob Scherr

! Natural Resources Defense Council, I nc .

1725 I Street, NW, #600 Washington, D.C. 20006 (202) 223-8210 l

Attorneys for Natural Resources Defense Council, Inc., and L the Sierra Club i

Dated: April 26, 1983

April 26, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Adminstrative Judges:

Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

)

UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION )

TENNESSEE VALLEY AUTHORITY ) Docket No. 50-537

)

(Clinch River Breeder Reactor)

)

)

AFFIDAVIT OF THOMAS B. COCHRAN I, Dr. Thomas B. Cochran, being duly sworn, depose and say: '

l. I am employed as a Senior Staff Scientist by the Natural Resources Defense Council, Inc., and, as such, I am duly authorir.ed to execute the foregoing answers to interrogatories.

2. The foregoing answers are true and correct to the best of my knowledge and belief.

$0 BC~O-Dr. Thomas B. Cochran Subscribed and sworn to before me this 26th day of April 1983.

b-A NNotary u&. Public N$ av My, Cewnizion Expicca JQ 31, . . . .

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00;nETE0 m:

l CERTIFICATE OF SERVICE

' '83 APR 26 P4:27 I hereby certify that copies of INTERVENORS' SECOND SET OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUEST TO PRODUCE TO STAFF and INTERVENORS' SECOND SET OF CONSTRUCTION PERMIT N J ,-

INTERROGATORIESANDREQUESTTOPRODUCETOAPPLICANTS'were delivered this 26th day of April 1983 by hand

• or by first class mail upon:

• Marshall E.. Miller,.Esq.

Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory' Commission 4350 East West Highway, 4th floor Bethesda, MD 20014

• Gustave A. Linenberger Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway, 4th floor Bethesda, MD 20014

• Sherwin E. Turk, Esq.

i Stuart Treby, Esq.

Gary S. Mizuno, Esq.

Elaine I. Chan, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, MD 20014

• Atomic Safety and Licensing Appeal Board

U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555

• Atomic Safety & Licensing Board Panel

, U.S. Nuclear Regulatory Commission i

1717 H Street, NW, Room 1121 Washington, D.C. 20555

• Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555 (3 copies)

• Indicates hand delivery.

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Certificate of Service - 2

• R. Tenney Johnson, Esq.

Leon ~Silverstrom, Esq.

Warren E. Bergholz, Jr.,-Esq.

William D. Luck, Esq.

Office of General Counsel r

U.S. Department of Energy 1000 Independence Ave., SW, Rm. 6A245 Washington, D.C. 20585

• George L. Edgar, Esq.

Irvin N. Shapell, Esq.

Thomas A. Schmutz, Esq.

Gregg A. Day, Esq.

Frank K. Peterson, Esq.

Morgan, Lewis & Bockius 1800 M Street,-NW, 7th Floor Washington, D.C. 20036 Dr. Cadet H. Hand, Jr., Director Bodega Marine Laboratory University of California P.O. Box 247 West Side Road Bodega Bay, CA 94923 (Federal Express Mail)

Herbert S. Sanger, Jr., Esq.

Lewis E. Wallace, Esq.

James F. Burger, Esq.

W. Walker LaRoche, Esq.

Edward J. Vigluicci, Esq.

Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive l Knoxville, TN 37902 l

William M. Leech, Jr., Esq.,

i Attorney General l William B. Hubbard, Esq.,

Chief Deputy Attorney General Michael D. Pearigen, Esq.

State of Tennessee Office of the Attorney General i 450 James Robertson Parkway i Nashville, TN 37219 Lawson McGhee Public Library 500 West Church Street Knoxville, TN 37219 l

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.V Certificate of Service - 3 William E. Lantrip, Esq.

City Attorney Municipal Building P.O. Box 1 Oak Ridge, TN 37830 i Oak Ridge Public Library Civic Center Oak Ridge, TN 37830 Joe H. Walker 401 Roare Street Harriman, TN 37748 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, TN 32219 2.n ~

j S. hcob Scherr l

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