ML20072R739

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Eighth Set of Interrogatories on Contentions Re ALARA & Emergency Planning.Certificate of Svc Encl.Related Correspondence
ML20072R739
Person / Time
Site: Clinch River
Issue date: 04/01/1983
From: Edgar G, Luck W
ENERGY, DEPT. OF, PROJECT MANAGEMENT CORP.
To:
National Resources Defense Council, Sierra Club
References
NUDOCS 8304060297
Download: ML20072R739 (19)
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Text

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4/1/83 astusoc % n ,y ,,; egg UNITED STATES OF AMERICA [' -f NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

APPLICANTS' EIGHTH SET OF INTERROGATORIES TO INTERVENORS, NATURAL RESOURCES DEFEN$E COUNCIL, INC.

AND THE SIERRA CLUB Pursuant to 10 C.F.R. $ 2.740(b), the United States Department of Energy and Project Management Corporation, for themselves and on behalf of the Tennessee Valley Authority (the Applicants), submit the following interrogatories to Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, These interrogatories must be answered fully, within 14 days in writing and under oath, by one or more representatives of NRDC or the Sierra Club who have personal knowledge of the matters g herein.

In addition to providing the direct answer to each co n 8 interrogatory, where applicable, please provide the following:

$5 og (a) Identify all documents and studies, and the parti-g cular parts thereof, relied upon by Intervenors, now or in the

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l past, which serve as the basis for Lne answer. In lieu thereof, at Intervenors' option, a copy of such document and study may be attached to the answer.

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

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

(d) Identify the expert (s), if any, which Intervenors intend 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 Intervenors l have in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Applicants.

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INTERROGATORIES CONTENTION 11 (AIARA)

1. Identify and describe in detail all analyses, statements and conclusions contained in Chapters 11 and 12 of the PSAR with Which you are in disagreement. The response to this interrogatory must include a detailed description or explanation of all bases for Intervenors' disagreement.
a. As to each such analysis, statement or conclusion, describe all analyses performed by Intervenors Which support Intervenors' position.
b. Identify any documents Which support the bases for Intervenors' disagreement.
2. Identify and describe in detail all analyses, statements and conclusions contained in Chapters 11 and 12 of the SER with Which you are in disagreemen.'.. The response to this interrogatory must include a detailed description or explanation of all the bases for Intervenors' disagreement.
a. As to each such analysis, statement or conclusion describe all analyses performed by Intervenors Which support Intervenors' position.
b. As to each such analysis, statement or conclusion, identify any documents Which support Intervenors' position.
3. State Whether Intervenors agree with the source terms contained in Chapter 11 and 12 of the PSAR.
a. If Intervenors disagree with any of the source terms, describe in detail the bases for the disagreement includ--

ing a description of any changes in methodology or data which Intervenors believe would be appropriate.

b. Identify any documents Which support Inter-venors' response to this interrogatory,
4. In considering occupational exposures at CRBRP, identify the nuclides Which Intervenors believe are of importance.
a. As to each nuclide identified above, state the basis for Intervenors' belief that it is of importance in considering occupational exposures at CRERP.
b. Identify all documents Which support Inter-venors' response to this interrogatory.
5. State whether Intervenors believe that Reg. Guides 8.8 and 8.19 provide cypropriate methods, approaches and objectives for ensuring that occupational radiation exposures at CRBRP will be as low as is reasonably achievable.
a. If Intervenors disagree, describe in detail the methods, approaches, and objectives which Intervenors believe should be used for ensuring that occupational radiation exposures at CRBRP will be ALARA. The answer to this interrogatory must include a detailed description of the bases for Intervenors' alternate methods, approaches or objectives.
b. If Intervenors agree with any or all of the methods, approaches, and objectives, identify specifically those with Which Intervenors agree.
c. Identify all documents Which support Inter-venors' response to this interrogatory.
6. Identify any design objectives or limiting con-ditions contained in 10 C.F.R. $ 50, Appendix I which Intervenors believe may not be appropriately applied to CRBRP.
a. As to each design objective or limiting con-dition identified above, describe in detail the basis for Intervonors' belief that it cannot be applied to CRBRP.
b. Describe in detail any alternate design objec-1 tives or limiting conditions Which Intervenors contend should be applied to CRBRP, including the basis for the alternative.
c. Identify any documents Which support Inter-
venors' response to this interrogatory.
7. State Whether Intervenors agree that the calcula-tion of public exposures over a 50 mile radius from CRBRP is appropriate for purposes of determining that radiation exposures to the public are ALARA.
a. If Intervenors disagree, identify the geo-graphic area Which Intervenors believe should be considered and describe in detail the basis for that geographic araa.
b. Identify all documents Which support Inter-venors' response to this interrogatory.

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8. State Whether Intervenors agree that in calculating public exposures, a fifty year dose commitment factor is appropriate for purposes of determining that radiation exposures to the public due to normal operation of CRBRP are AIARA.
a. If Intervenors disagree, identify the dose commitment period Which Intervenors believe should be considered and describe in detail the basis for that period.
b. Identify all documents Which support Inter-vsnors' response to this interrogatory.
9. State Whether Intervenors agree that no plutonium will be released offsite during normal operation of CRBRP includ-ing expected operational occurrences.
a. If Intervenors disagree, describe the precise i events Which Intervenors believe will result in the release of plutonium and describe the release pathway Which will result in the offsite release of plutonium during normal operation of CRBRP.
10. State Whether Intervenors agree that about 90 percent of the tritium generated at the reactor will diffuse through the cladding into the sodium coolant, where it will be removed by sodium cold traps.
a. If Intervenors disagree, describe in detail the basis for the disagreement and specify the percentage of tritium Which Intervenors contend will be removed by sodium cold traps.

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b. Identify any documents Which support Inter-venors' response to this interrogatory.
11. Identify any design alternatives not presently incorporated in CRBRP Which Intervenors contend should be incorporated in CRBRP's design in order to meet the ALARA j objective.
a. As to each design alternative, describe the purpose of the alternative, the cost of the alternative, and the likely reduction in radiation exposure which will result if the alternative is incorporated in the CRBRP design.

i b. Are Intervenors aware of any design alterna-tives, other than those identified in Regulatory Guide 1.110 Which they contend should be incorporated in CRBRP's design in order to meet the ALARA objective?

c. Identify all documents Which support Inter-venors' response to this interrogatory.
12. Describe in detail any procedures not already planned for CRBRP Which Intervenors contend should be implemented in order to ensure that occupational radiation exposures at CRBRP i are ALARA.
a. As to each such procedure, describe the cost of implementation and the likely reduction in radiation exposure Which would result from its implementation at CRBRP.
b. Identify all documents supporting Intervenors' response to this interrogatory.

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13. Describe in detail Intervenors' understanding of the controlling mechanisms and rates for the movement of fission products, plutonium, and corrosive products in CRBRP from the j sodium coolant to the cover gas during normal operation.

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a. Identify all documents Which support Inter-venors' response to this interrogatory.
14. State Whether Intervenors believe that significant (non-negligible) direct radiation exposure (" shine" exposure) is likely to occur either on-site or off-site as a result of normal operation of CRBRP, including expucted operational occurrences.
a. If so, describe in detail the sequence of events Which would lead to significant (non-negligible) direct radiation exposure during normal operation, including expected operational occurrences.
b. Identify all documents Which support Inter-venors' response to this interrogatory.

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15. Describe in detail the dosimetric models Which Intervenors believe should be used for each organ in calculating occupational and public exposures due to normal operation of CRBRP including expected operational occurrences.
a. Identify all documents which support Inter-venors' response to this interrogatory.
16. State Whether Intervenors disagree with the calcu-lation of releases due to liquid radwaste, gaseous radwaste or solid radwaste contained in the PSAR.

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a. If so, describe in detail the basis for Inter-venors' disagreement including a description of any analysis performed by Intervenors, if any.
b. Identify all documents Which support Inter-venors' response to this interrogatory.
17. State Whether Intervenors agree that the cold boxes planned for CRBP.P to control releases represent the most advanced state of technology.
a. If Intervenors disagree, describe the tech-
nology Which Intervenors believe should be incorporated in CRBRP in place of the cold boxes for controlling releases.
b. Identify all documents Which support Intervenors' response to this interrogatory.
18. Identify all documents Which Intervenors intend to rely upon at the Construction Permit hearing in addressing Contention 11 (ALARA).

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19. Identify all experts Intervenors intend to call as

, witnesses at the Construction Permit hearing on Contention 11 l

(ALARA).

a. As to each such expert, provide the following informations (1) educational background; 1

(2) employment background; (3) a listing of all nuclear plants reviewed by the expert for purposes of ALARA

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i (4) a listing of all hearings in Which the expert appeared as an ALARA witness; (5) a listing of all articles, books studies or other documents prepared by the expert on the ALARA objective.

20. With regard to Dr. Thomas Cochran, provide the information requested in Interrogatory 19.

CONTENTION (Emergency Planning)

21. Identify any atatements, analyses, or conclusions in the PSAR, Chapter 13, Emergency Planning, with which Inter-venors disagree.
a. As to each statement, analyses or conclusion identified above, describe in detail the basis for Intervenors' disagreement.
b. Identify all documents Which support Inter-venors' response to this interrogatory.
22. Identify any statements, analyses, or conclusions t

in the SER, Chapter 13, Emergency Planning, with which Inter-venors disagree.

a. As to each statement, analyses or conclusion identified above, describe in detail the basis for Intervenors' disagreement.

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b. Identify all documents which support Intervenors' response to this interrogatory.

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23. Describe in detail the methodology Which Intervenors believe should be used in developing a bone dose value for evacuation Protective Action Guides (PAG),
a. Describe in detail any analyses, calculations or studies performed by Intervenors in developing a bone dose PAG.
b. Identify all documents used by Intervenors in responding to this interrogatory.
24. Describe in detail the basis for the statement in Contention 9(a) that the PSAR contains " insufficient information."
a. Describe in detail the information Which Intervenors believe was omitted from the PSAR.
b. Describe in detail the information Which Inter"3nors believe is insufficient in the PSAR.
c. Identify all documents Which support Intervenors' response to this interrogatory.

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25. Describe in detail the local emergency response needs and capabilities Which Applicants have " failed to account properly for" as stated in Contention 9(b).

! a. In responding to this interrogatory, separately l

provide a description of:

(1) the identity of the local communities Whose response needs and capabilities were not properly accounted for.

l (2) As to each community, the precise needs and capabilities not properly accounted for.

b. Identify all documents Which support Intervenors' response to this interrogatory.
26. Describe in detail the boundaries for the plume exposure pathway and ingestion pathway EPZ's Which Intervenors contend should be adopted at CRBR.
a. Identify any documents supporting Intervenors' response to this interrogatory.
27. Describe in detail any " major impediments to the evacuation or taking of protective action" in the event of an accident at CRBRP. (See Contention 9(c)).
a. Identify all documents which support l

! Intervenors' response to this interrogatory.

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28. Describe in detail the basis for Intervenors' Contention 9(c) that the PSAR contains " insufficient analysis of the time required to evacuate various sectors and distances within the plume exposure pathway EPZ for transient and permanent population." The response to this interrogatory must identify the portion (s) of the analysis with which Intervenors disagree l

l and a description of the precise nature of Intervenors' disagreement'.

a. Describe any analysis undertaken by Intervenors of the time required for evacuation.

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b. Identify all documents Which support Intervenors' response to this interrogatory.
29. Describe in detail the basis for Intervenors' Contertion 9(d) that the PSAR contains " insufficient information."
a. Describe the types or categories of additional information Which Intervenors believe are necessary to ensure the

" compatibility of proposed emergency plans . . . with facility design features."

b. Describe the types or categories of additional information Which Intervenors believe are necessary to ensure

" compatibility of the proposed emergency plans ... with site layout."

c. Describe the types or categories of additional information Which Intervenors believe are necessary to ensure

" compatibility of the proposed emergency plans with ... site location."

d. Identify all documents Which support Intervenors' response to this interrogatory.
30. Describe in detail the basis for Intervenors' Contention 9(e) that the PSAR contains " insufficient information."
a. Describe the types or categories of information Which Intervenors centend must be in the PSAR in regard to:

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(1) authorization procedures; (2) notification procedures; (3) instruction procedures. -

b. Identify all documents Which support Intervenors' response to this interrogatory.
31. Describe in detail the basis for Intervenors' Contention that "special measures" must be taken into account in CRBRP's emergency plan "to cope with a CDA."
a. Define the word " increased" as used in Contention 9(f).
b. Describe in detail the basis for Intervenors' contention that " protective, evacuation and monitoring measures" must be " increased."

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c. Describe the precise " protective measures" that should be " increased."
d. Describe the precise evacuation measures Which should be " increased."

j e. Describe the precise monitoring measures Which should be " increased."

f. Describe the " increased" protective measures Which Intervenors believe are necessary at CRBRP.

j g. Describe the " increased" evacuation measures ,

l Which Intervenors believe are necessary at CRBRP.

l h. Describe the " increased" monitoring measures l Which Intervenors believe are necessary at CRBRP.

i. Define the term " reduced" as used in Contention 9(f).
j. Explain why Intervenors believe there will be

" reduced response time" at CRBRP.

k. Describe the "special protective action levels" which Intervenors believe are necessary for CRBRP.
32. Identify any experts who Intervenors intend to call as witnesses in support of Contention 9.
a. As to each such expert, provide the following information:

(1) educational background; (2) employment background; (3) a listing of all emergency plans for nuclear power plants reviewed by such expert; (4) a listing of all hearings in which the expert has testified as a witness on emergency planning at nuclear power plants; (5) a listing of all articles, books, studies or other documents prepared by the expert on emergency planning; (6) a listing of all emergency plans for nuclear plants prepared by the expert in whole or in part.

33. With regard to Dr. Thomas Cochran, provide the information requested in Interrogatory 32.

eorge L. Edgar W /W/

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Attorney For Project Management Corporation

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William D. Luck Attorney For The Department of Energy l

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UNITED STATES OF AMERICA NUCLI.AR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

}

DNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

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

Chairman l Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comission l

East-West Towers 4350 East-West Highway Bethesda, Maryland 20014 (2 copies by hand)

Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California West Side Road Bodega Bay, California 94923 (Air Express)

Pe. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comission East-West Towers 4350 East-West Highway Bethesda, Maryland 20014 (by hand)

Sherwin E. Turk, Esq.

Stuart Treby, Esq.

Office of Executive Legal Director U. S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, Maryland 20014 (2 copies by hand)

  • Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission

' Washington, D. C. 20555

  • Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555
  • Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Commission

' Washington, D. C. 20555 (original, 3 copies, and return copy)

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Michael D. Pearigen, 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 37830 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 West Summit Hill Drive (2 copies)

Knoxville, Tennessee 37902

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3-l Dr. Thomas Cochran Barbara A. Finamore, Esquire Natural Resources Defense Council 1725 Eye Street, N.W., Suite 600 Washington, D. C. 20006 ( 2 copies by hand)

Ellyn R. Weiss, Esquire Harmon & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D. C. 20006 Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge Municipal Building Post Office Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esquire l

Warren E. Bergholz , Jr. , Esquire William D. Luck, Esquire

- U. S. Department of Energy 1000 Independence Avenue, S.W.

Room 6B-256--Forrestal Building Washington, D. C. 20585 (4 copies by hand)

Eldon V. C. Greenberg, Esquire Galloway & Greenberg 1725 Eye Street, N.W., Suite 601 Washington, D. C. 20006 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 M /t or L.' Edgar At ey for Proj ect Nkna ent Corporation DATED: April 1, 1983

  • / Denotes hand delivery to 1717 "H" Street , N.W., Washington, D.C.

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