ML20073G471

Response to 830401 Eighth Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20073G471
Person / Time
Site:	Clinch River
Issue date:	04/14/1983
From:	Finamore B National Resources Defense Council, Sierra Club
To:	JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
References
NUDOCS 8304180291
Download: ML20073G471 (20)

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DD(.MEIED April 14," '1983

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g3 [m j j na ro 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 )

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

)

(Clinch River Breeder Reactor Plant) )

)

)

RESPONSE OF INTERVENORS NATURAL RESOURCES

DEFENSE COUNCIL, INC., AND THE SIERRA CLUB TO APPLICANTS' EIGHTH SET OF INTERROGATORIES

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DATED APRIL 1, 1983 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, hereby respond to Applicants' Eighth Set of Interrogatories dated April 1, 1983.

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8304180291 830414 PDR ADDCK 05000537 g PDR

Interrogatories CONTENTION 11 (ALARA)

1. Identify and describe in detail all analyses, stTtements 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 i

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 disagreement. The response to this interrogatory

, must incit*3e 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 4 = ants which support Intervenors' position.

3. State whether Intervenors agree with the source terms 1

contained in Chapter 11 and 12 of the PSAR.

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a. If Intervenors disagree with any of the source terms, describe in detail the bases for the disagreement including a description of any changes in methodology or data which Intervenors believe would be appropriate.

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

4. In considering occupational exoostures at GBRP, 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 CRBRP.

b. Identify all rh '= ants which support Intervenors' response to this interrogatory.

5. State whether Intervenors believe that Reg. Guides 8.8 and 8.19 provide appropriate 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 objectises which Intervenors believe should be used for ensuring that occupational radiation exposures at CRBRP will be AIARA. The answer to this interrogatory must incitrie 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 i Intervenors agree.

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c. Identify all rh'im nts which support Intervenors' response to this interrogatory.

6. Identify any design objectives or limiting conditions contained in 10 C.F.R. 6 50, Appendix I which Intervenors believe may not be appropriately applied to CRBRP.

a. As to each design objective or limiting condition identified above, describe in detail the basis for Intervenors' belief that it cannot be applied to CRBRP.

Describe in detail any alternate design objectives or b.

limiting corviitions which Intervenors contend should be applied to CRBRP, including the basis for the alternative.

c. Identify any dev'i=nts which support Intervenors' response to this interrogatory.

7. State whether Intervenors agree that the calculation of public exposures over a 50 mile radius from CRBRP is appropriate for purposes of determining that radiation exInsures to the public are i

AIARA.

a. If Intervenors disagree, identify the geographic area which Intervenors believe should be considered armi describe in detail the basis for that geographic area.

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

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.

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a. If Intervenors disagree, identify the dose commitment period which Intervenors believe should be considered and describe in detail the basis for that period.

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

9. State whether Intervenors agree that no plutonium will be released offsite during normal operation of CRBRP including expected operatior.al occurrences.

a. If Intervenors disagree, describe the precise events which Intervenors believe will result in the release of plutonium I 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 tha reactor w'11 diffuse through the cladding into the sodium coolant, where it will be removed by sodium i

i oold traps.

a. If Intervenors disagree, describe in detail the basis for the disagreement arx1 specify the percentage of tritium which Intervenors. contend will be renoved by sodium cold traps.

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b. Identify any documents which support Intervenors' 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 AIARA objective.

a. As to each design alternative, describe the purpose of the alternative, the cost of the alternative and the likely i

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2 reduction in radiation exposure which will result if the alternative is incorporated in the CRBRP design.

b. Are Intervenors aware of any design alternatives, other than those identified in Regulatory Guide 1.110 which they conterd should be incorporated in CRBRP's design in order to meet the AIARA objectiv:?

c. Identify all h==nts which support Intervenors' 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 are AIARA.

a. As to each such procedures, describe the cost of 4

implementation and the likely reduction in radiation ex;osures 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 i

controlling mechanisms and rates for the novement of fission products, plutonium, and corrosive products in CRBRP frm the sodium coolant to the cover gas during normal operation.

a. Identify all h==nts which support Intervenors' 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 expected operational occurrences.

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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 Intervenors' resp mse to this interrogatory.

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 h=nants which support Intervenors' response to this interrogatory.

16. State whether Intervenors disagree with the calculation of releases due to liquid radwaste, gaseous radwaste or solid radwaste contained in the PSAR.

a. If so, describe in detail the basis for Intervenors' disagreement including a description of any analysis performed by Intervenors, if any.

b. Identify all A v,waants t which support Intervenors' respmse to this interrogatory.

17. State whether Intervenors agree that the cold boxes planned for CRBRP to control releases represent the most advanced state of technology.

a. If Intervenors disagree, describe the technology which Intervenors believe should be incorporated in CRBRP in place of the i

cold M xes for controlling releases,

b. Identify all atv'unants which support Intervenors'

response to this interrogatory.

18. Identify all h = nts which Intervenors intend to rely upon at the Construction Permit hearing in adiressing Contention 11 (AIARA).

19. Identify all experts Intervenors inteni to call as witnesses at the Construction Permit heariry on Contention 11 (AIARA) .

a. As to each such expert, provide the following information:

(1) educational background; (2) employment backgrounS; (3) a listing of all nuclear plants reviewed by the expert for purposes of AIARA; (4) a listing of all hearings in which the expert appeared as an AIARA witness; (5) a listing of all articles, books studies or other htmants prepared by the expert on the AIARA objective.

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

Response

Intervenors hereby withdraw Contention 11(a) from consider-ation at the CP licensing stage; consequently, responses to these

. interrogatories ar3 not given. Intervenors reserve the right to raise limited ALARA issues at the Operating License (OL) hearing; for example, regarding establishment of dose guidelines for l

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female workers to protect the fetus, and establishment of age-specific occupational dose guidelines to reduce genetic and somatic risks. We believe these are more appropriate OL, rather than CP, issucs.

i CONTENTION 9 (Emergency Planning)

Interrogatory

21. Identify any statements, analyses, or conclusions in the PSAR, Chapter 13, Emergency Planning, with which Intervenors -

disagree.

a. As to each statement, analysis or conclusion identified

! above, describe in detail the basis for Intervenors' disagreement.

i b. Identify all h= ants which support Intervenors' response to this interrogatory.

i Response To the best of Intervenors' knowledge most of Chapter 13 is irrelevant to Contention 9 (Emergency Planning). Our comments are limited to PSAR Section 13.3. There are many statements on pp. 13.3-1 to 13.3-9 that use the terms " ...will be..." or

"...will ensure...", or "...will..." Intervenors are unable to either agree or disagree with these statements because they either (a) call for a legal conclusion, (b) are predictive in nature and we have no basis for knowing whether they will occur, ,

or (c) we have insufficient information to make a reasoned l

judgment. With regard to the remainder of 13-1 to 13-2, and all of pp. 13-10 to 13-13, Intervenors have no basis for agreeing or disagreeing with these sections. Regarding the analysis in l

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Section 13.3A, our criticisms of the SSST analysis given at the LWA-1 hearings are applicable. In addition, we do not agree that assuming no fallout during cloud passage is necessarily conservative for strong gamma emitters such as Na-24, because of the potentially high dosage associated with groundshine from fallout of these nuclides. Intervenors also note the lack of PAGs for bone exposure. These comments should be considered preliminary as our analysis of PSAR Section 13.3 is not yet completed.

Interrogatory _

22. Identify any statements, analyses, or wnclusions in the SER, Chapter 13, Emergency Planning, with which Intervenors disagree,

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

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

Response

Based on our preliminary assessment of SER Section 13.3, Intervenors disagree with the statement that: "the plume exposure pathway emergency planning zone (EPZ) established for the CRBR site is about 10 miles in radius." We do not believe this EPZ is established. We disagree with the treatment of CDAs as outside the design basis, and with the radiological analysis of the SSST, as indicated in the LWA-1 proceeding and Intervenors' LWA-1 evidence. We also disagree with the statement that "[t]he use of the SSST is conservative, since it envelopes the most serious design-basis accidents analyzed in the PSAR. Our

I disagreement is for reasons detailed in our LWA-1 evidence.

Our comments regarding the predictive statements, e.g.

"...will..." in response to Interrogatory 21 apply here as well. Intervenors are unable to agree or disagree with these conclusory statements by the Staff because they call for a legal conclusion or because we have insufficient information to make a reasoned judgment. We don't disagree that the Staff reached these conclusions.

Interrogatory

23. Describe in detail the methodology which Intervenors believe should be used in developing a bcne dose value for evacuation Protective Action Guides (PAG).

a. Describe in detail any analyses, calculations or studied performed by Intervenors in developing a bone dose PAG.

b. Identify all documents used by Intervenors in resporxling to this interrogatory.

Response

Intervenors have not yet decided what methodology is appropriate.

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 Intervenors believe is insufficient in the PSAR.

c. Identify all documents which supsort Intervenors' response to this interrogatory.

Response

Intervenors hereby withdraw contention 9(a) from consider-ation at the CP licensing stage, and therefore no response is 1

necessary.

Interrogatory

25. Describe in detail the local mergency response needs and capabilities which Applicants have " failed to account properly for"  ;

as stated in Contention 9(b). ,

j a. In responding to this interrogatory, separately provide '

a description of:

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

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

b. Identify all h= ants which support Intervenors' respmse to this interrogatory.

Response

Intervenors hereby withdraw Contention 9(b) from consider-ation at the CP licensing stage, and therefore no response is necessary.

Interrogatory

26. Describe in detail the boundaries for the plume exposure pathway and ingestion pathway EPZ's which Intervenors contend should be a& pted at CRBR.

a. Identify any h= ants supporting Intervenors' response -

to this interrogatory.

Response

360'. Due to lack of information available on doses and ground contamination levels, a function of distance following CDAS, Intervenors are unable at this time to determine an

appropriate EPZ distance for plume exposure. Intervenors do not object to a 50-mile ingestion EPZ.

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 Intervenors' response to this interrogatory.

Response

The potential for high doses following a CDA prior to completion of evacuation.

(a) SER, Appendix A of evacuation times.

Interrogatory

28. Describe in detail the basis for Intervenors' Contention 9(c) that the PSAR contains " insufficient analysis of the time requirement 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 porticn(s) of the analysis with which Intervenars disagree arxi a description of the precise nature of Intervenors' disagreement.

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

b. Identify all h = nts which support Intervenors' response to this interrogatory.

Response

The PSAR analysis of evacuation times is limited to a 10-mile EPZ.

a. None to date.

b. PSAR, p. 13.3A-3.

l Interrogatory

29. Describe in detail the basis for Intervenors' Contention 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 "azapatability of proposed emergency plans ... with facility design features."

b. Describe the types or categpries of additional information which Intervenors believe are necessary to ensure the "compatability of proposed emergency plans ... with site layout."

c. Describe the types or categories of additional information which Intervenors believe are necessary to ensure the "compatability of proposed emergency plans with ... site location."

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

Response

Intervenors hereby withdraw Contention 9(d) from consider-ation at the CP licensing stage, and therefore no response is necessary.

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 4

Intervenors contend must be in the PSAR in regard to:

! (1) authorization procedures;

! (2) notification procedures; (3) instruction procedures. ,

Response

Intervenors hereby withdraw Contention 9(e) from consider-ation at the CP licensing stage, and therefore no response is necessary.

! Interrogatory

31. Describe in detail the basis for Intervenors' Contention

, that "special measure" must be taken into account in CRBRP's emergency plan "to cope with a CDA."

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a. Define the word " increased" as used in Contention 9(f).

I b. Describe in detail the basis for Intervenors' contention that " protective, evacuation and monitoring measures" must be " increased."

c. Describe the precise " protective measures that should i

be " increased."

d. Describe the precise evacuation measures which should be " increased."

e. Describe the precise monitoring measures whi'ch should be " increased."

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

g. Describe the " increased" evacuation measures which Intervenors believe are necessary at CRBRP.

h. Describe the " increased" nonitoring measures which Intervenors believe are n-my 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.

Response

Two principal bases for Intervenors' Contention 9(f) are:

(1) The time period available for evacuation is too short under some scenarios. Since the available evacuation time can not be confidently predicted in advance of a CDA, unlike the TMI accident, it would be prudent to call for full evacuacion as soon as a core melt-through appears imminent. (2) The potentially short evacuation time, release of plutonium and large quantities of Na-24, and the need to maintain a limited workforce at nearby facilities may require offsite decontamination facilities and public education on decontamination procedures,

a. The term " increased" as used by Intervenors in Contention 9(f) is synonymous with " additional."

b.-h. See discussion above.

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1. The term " reduced" as used by Intervenors in Contention 9(f) is synonymous with " shorter."

j. See SER Appendix A.4 and Attachment 1.

k. Intervenors believe it is necessary to establish PAGs for bone dose and guidelines for ground contamination levels for (a) evacuation, (b) reentry and (c) rehabitation.

Interrogatory

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 pwer 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, sttdies or other

&v - nts 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.

Response

No decision has been made to date in this regard.

Respectfully submitted, g , . _

/Y&rbaraA. Finamore j Natural Resources Defense Council 1725 I Street, NW, Suite 600 Washington, D.C. 20006 (202) 223-8210 Attorney for Intervenors Natural Resources Defense Council and Sierra Club

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April 14, 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 3reeder Reactor) )

)

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

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

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

h%w f3(c%_b-Dr. Thomas B. Cochran Subscribed and sworn to before me this 14th day of April 1983.

JaL Notary We Public Mz Cummis,;,,

F m Ims, gJuly

.; . 3;

CERTIFICATE OF SERVICE g, .

I horeby certify that copies of RESPONSE OF INTERVENORS NATURAL RESOURCES DEFENSE COUNCIL, INC., AND SIERRA CLUB)3TO;.?R 14 P3 :49 APPLICANTS' EIGHTH SET OF INTERROGATORIES DATED APRIL 1, 1983 were served this 14th day of April 1983 by hand

• or by first class mail upon:

3 .g, 1,: 71 N 6!"

• 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.

Stuart Treby, Esq.

Geary 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 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.

Certificate of Service - 2 R. Tenney Johnson, Esq.

Leon Silverstrom, Esq.

Warren E. Bergholz, Jr. , Esq.

William D. Luck, Esq.

Office of General Counsel 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 Knoxville, TN 37902 William M. Leech, Jr., Esq.,

Attorney General William B. Hubbard, Esq.,

Chief Deputy Attorney General Michael D. Pearigen, Esq.

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

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

City Attorney Municipal Building P.O. Box 1 Oak Ridge, TN 37830 Oak Ridge Public Library Civic Center Oak Ridge, TN 37830 Joe H. Walker 401 Roane Street Harriman, TN 37748 Commissioner James Cotham Tennessee Department of Economic and Community Developinent Andrew Jackson Building, Suite 1007 Nashville, TN 32219 Ba#bHra A. Findmore

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