ML20073P235
| ML20073P235 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/22/1983 |
| From: | Scherr S National Resources Defense Council, Sierra Club |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8304250080 | |
| Download: ML20073P235 (41) | |
Text
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ent.yETED April 22, '1983 e# '83 APR 22 P155
[ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .
ATOMIC SAFETY AND LICENSING BOARD '
M "CH Bef ore Administrative Judges:
Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.
Dr . Cadet H. Hand, Jr.
)
In the Matter of )
)
UNITED STATES DEPART) TENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-5 37 TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
)
)
RESPONSE OF INTERVENORS TO NRC STAFF FIRST SET OF CONFPRUCTION PERMIT INTERROGATORIES AND REQUESTS FOR ADMISSIONS TO NATURAL RESOURCES DEFENSE
, COUNCIL, INC. AND THE SIERRA CLUB l CONCERNING CONTENTIONS 1, 2, AND 3 (HCDAs)
DATED APRIL 8, 1983 Pursuant to 10 CFR $$ 2.742 and 2.740b, ard in accordance With the Board's Construction Permit Scheduling Order of March 29, 1983, Intervenors, Natural Resources Def ense Council, Inc.
and the Sierra Club hereby respond to NRC Staf f's First Set of Construction Permit Interrogatories and Requests for Admissions to Natural Resources Def ense Council, Inc . a nd the Sierra Club Concerning contentions 1, 2, and 3 (HCDAs).
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C304250080 830422 4 x PDR ADOCK 05000537 e O PDR R .
4 INTERROGATORIES Interrogatory 1(a)-1 List the relevant specific CER secticns ad sWeoctions '
which NRDC cczitands iWately discuss the Staff's conclusion that the probability of ATN3 or other CIA initiator occurrerne is aufficiently low that CIAs may be excluded frm the IRA envelope.
Response i 1(a)-3 Inte rvenors have not completed our review of the SER and theref ore cannot anowr this question at this time. The Staf f saf ety analysis as documented in the SEE is not based on quantitative probability, analyses and therefore it is safe to say that the SER as a whole is inadegaate in this regard .
Interrogatory 1(a)-2 For each SER section ad s@secticr1 listed by NRDC in -
its answer to Interrogatzy 1(a)-1, set forth with specificity why NRDC ccmteMs that these sections ad s§icns are imdecpate.
Response
1(a)-2 See Answer 1(a) above and Intervenors' testimony at the LWA-1 hearing regarding contentions 1-3.
l Interrogatory 1(a)-3 At diat probability of occurrence does NRDC conted that CIA initiatcrs are of sufficiently low likelihood that they can be erluded from the plant desicyl basis envelope? Set forth the bases for NRDC's answer.
Response
( Inte rvenors addressed this in our Response to Inte rrogatory l
l-la of Staf f's First Round of Discovery to NRDC (May 6, 1982)
and in our LWA-1 Testimony. Inte rvenor s' position in this regard has not changed.
Interrogatory
,, 1(a)-4 List all A'IMil events an! Ci'A initiators which IRIX:
.ccntends may lead to CDhs.
Response
- The kinds of events that can lead to CDAs are amply l described in numerous reports on CIRa including, f or axan ple ,
L
, CRBRP-1. See also Intervenors' LM-1 Testimony.
l Interrogatory ,
t 1(a)-5 Dessibe in detail the sequence of e' rents by 411dt A'IWi eve'its cr CIA initiatas may lead to CIAs.
Response ,
See CRBR-1 and other reports on CDAs and our LR-1 Te st imony. See Response to Interrogatory 2(b) of Applicants' i Fourth Set of Interrogatories to Intervenors.
j Interrogatory i
1(a)-6(a) Define, " reliable &ta", as that term is usei in Centention 1(a). Set forth the hamaa for NRDC's definiticn.
(b) Set forth the criteria, data, or other factors that j NRDC ccnterds should be utilizei in determinirs diether &ta is
" reliable" .
i Response You have asked this Interrogatory previously. Inte rvenor s' answer remains the same. The basis of Intervenors definition is r that this is what we mean by the te rms .
o Interrogatory .
1(a)-7 In NRDC's May 6,1982 response to Interrogatory 1-1.2 of the Staff's First Round of Discovery, filed on April 15, 1982, 250C stated that it has not rea:hed a final determiration regarding the appropriate operational definition cf " credible" as used in 10 CFR 100. MtDC alm stated that it alm hai not finally determined the level of confidere req 2 ired to judJe tether events are "ccedible" or not credible." Has a final determitatim now been readied? If m state what it is. If rot, state what it will be providei.
Respon se Tes. It is given in Interveaocs' L R -1 testimony.
Intutrogntory ,
1(a)-8 In NRIX"'s May 6,1982 resp, nae to Interrogatory 1-3.0 of the Staff's First Reuni of Discovery, filed on April 15,1982, NPDC stated that "me must be able to deemstrate that the chta base den uset in the matel ce programs is a scientifically validated procature fcr determining that the predicted results represent an accumte estimate of the true values, that is, accurate to within the stated confide.re intervals." Define what IRDC considers an ao:cptable descristation of a scientifically validated pecx:edure.
Prrvide the hises for NRDC's anmer.
Resinnse Generally accepted procedures used in the fields of the applied sciences. Intervenors believe applicable experimental data and the scientific method should be used. See response to
- Interrogatory 2-14(b) of Staf f's First Round of Discovery to NRDC, e t al . (May 6, 1982) .
l Interrogatory l
1(a)-9 Define " scientifically validated procsiure" as ussi by NRDC in its response to Interrogatory 2 of " Natural Resources Defense Council, et al. Response to Applicants' Interrogatories Dated Novenber 187976," dated Deember 9,1975, in this proceeding.
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Response
" Scientifically validated procedure" means accepted procedures used in the fields of the applied sciences. See Response to Interrogatory 2-14(b) of S taf f's First Round of Discovery to NRDC et' al. (May 6, 1982 ) .
t l
l Interrogatory i
1(a)-lO Provids a list of what MdX: contrrnds to be
" scientifically vali&ted peccedures" for ektermirdng the reliability of GER shr.-dows systetis. Cascribe the cource of these prcx:edures, ard the beess fut canctuding t&t these >
procsiures are scientificMly valihred. ;
a
Response
i Intervenors do not have a list. See rertpense to 1(a)-9
'above.
i Interrogatory 1(a)-ll Specify the bases for MIDC's answer to Interrogatory 1(a)-9 indicating dat acx:eptarce criteria, metholology, &ta ard l
tests you consider nmessary ard sufficient to establish that a l
pecx:e&are for determining reliability of CRBR shut-dows systems is
" scientifically validated."
Response
Inte rvenor s' point is that the applicable experimental data l and the scientific method should be utilized as opposed to arbitrary, unfourxled and superstitious assumptions as well as l nuclear theology and dogma' and unsupported " engineering i
judgments."
.. . . - . . _ . - . _ . . . - . _ _ _ - . - +. . . . _ _ - . .
i l
o-CONTENTION 1(b)
Interrogatory 1(b)-1 List all relevant sections ard s@ sections of the SER tAich NRDC contends inadegately discuss the Applicants' reliability grogram as a buis for elimimting Cth: ftun the DBA envelope.
Res ponse, Appli cants' reliability program is discussed in Appendix C, Interrogatory i.
1(b)-2 Set fcrth in detail, in NRIC's ovi vords, and without reference or citation to arr,thar docummit, w1y the Staff's analysis
Responso r
Intervenors have not completed our review of the SER ur.1 therefore cannot answer this question. Intervenors' general concerns have been set forth in our LWA-1 testimony.
Interrogatory l 1(b)-3 List all methodologies whid1 NtDC contends are i, acceptable for predicting the probability of CIRs. Set farth the bases fcr MtDC's'anneer.
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Response
Scientific method. It is soundly based on over 300 years of experience .
i Interrogatory
> 1(b)-4 Define, " sufficient failure utdel (sic) data", as that term is used in Contenticn 1(b)(1). Set forth the bases for NRDC's definition.
o-
Response
The definition of these words can be found in Webster's Collegiate Dictionary. Intervenors mean input data of such quality that' one can demonstrate by propagation of uncertainties that the result meets the applicable criterion taking into l
account all urcertainties.
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Interroga_ tog 1(b)-5 What failure made da a dms 1EDC concider nrcasary to ,
validly employ f ault tree and ovmt tree analyses in assessing CIER reliability? Set fath the bases fx IEDC's ar.wr.
Response
~4hatever it takes to demonstrate the probability of a CEA is 4
suf ficiently low to justify exclusion of the CDA f ron the ,
containment design basia . Intervenors do not claim this can be done for CRBR given the design ard timing constraints.
Interrogatory 1(b)-6 Define, " Applicants' trojected data base", as that phrase is uset in Contenticn 1(b). Set forth the bases fx NRDC's definition.
Response
The -input data used in Applicants' reliability analyses.
Interrogatory -
1(b)-7 List an1 descibe with partiof.arity where ani why the ,
Applicants' an4/or Staff's &ta base is indequate.
Response
Inte rvenor s' criticisms of Staf f reliability analysis and the reasons why we believe it supports incorporating the CDA
- o within the containment design basis envelope were presented in our testimony on Appendix J at the LNA-1 hearings. Interv enor s also believe that Applicants' comprehensive PRA analysis 'should have been completed prior to the CP, rather than the OL.
i i Interrogatory
- . 1(b)-s . IJst the c,. edible failure sodes or human elemasts that i 1300 centmis are rot, but should be inclxlet in the reliability prograu.
Response
The burden of proof is riot on Intervenors. The point is
,- that PRA is a .usef ul technique f or identif ying such f ailure modes
. and 'a comprahensive PRA should have been performed prior to the CP.
Interrogatory 1(b)-9 Specify each aspect of the Applicant's "reliebility program" that N3DC conterds is iWute, or whidi contributes .to the imbility of the " reliability grogram," even if implenented, to elimiste CIRs as IBAs.
l Response The primary problems with Applicants' reliability program that we have identi fied to date are (1) the criteria have been wa te red down; (2) the timing of the program is such that a comprehensive PRA will not be available in time f or the CP decision. Inte rvenors have not seen the bulk of the quantitative ,
reliability data gene ra ted by Applicants and consequently cannot provide a more complete answer.
o
' Interrogatory 1(b)-10 What level of experience, within the meaning of NRIC's response runber 2(a) under Contention 2(b) of its Jaruary 13, 1977 "Adnissions by Natural Resources Defense Council to Applicants' Request (First Set)" does NIqDC contard is auf ficiently extensive, with respect to the developent of reliability &ta for instrtanestation and electronic equipnent similar.to that usal in the CIqBR shatdom ard sMtdom heat removal systems, to permit that
&ta to be a useful predictcr of the reliability of the similar CIqBR eqaignent.
Response
-The experience would have to be (a) relevant to CRBR, (b) ,
suf ficiently extensive sudt that when the confidence limits (due i l' to statisticM and other uncertainties) are propagated through ,
the appropr?ats model the results allow one to confidently predict that the appropriate criteria are met.
t Jntereogaterv 1(b)-11 Define, "sufficiently low protability", as that term ic ustd in Contenticn 1(b)-3. Provide the hamaa for NRDC's
- definiticrt.
. Response l Small enough to demonstrate that the CDA frequency is less l
r than the criterion Intervenors presented in our LWA-1 testimony.
l Interrogatory l
1(b)-12 Specify the bases for selecting the probability identified in respartse to Interrogatory 1(b)-11 above, iniicating
, what acceptance criteria, methodologies, data, ard tests NRDC i
relies on in stpport of these bases.
Response
Inte rvenors presented the bases in our LWA-1 testimony.
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C Interrogatory 1(b)-13 Asstming the data base is established as postulated in the s@ contention, what does NRDC ccntend precludes establishing that CIns hwe a sufficiently low protabilitiy as defined above?
Response
The current CRBR design.
Interrogatory 1(b)-14 .9egwilts Contantion 1(b)(4): Set fcrth ulth speci ficity NRDC'r basis f.x amaarting that Applicants must cmplets the test program used for their relistilicy trogram trior to their proja-ted data for completion of construction of the CRE.R. .
Re'spo nse Inte rvencr s' basis is common sense. It would be much less usef ul if the tests were completed af ter the construction ms compl e ted . In the absenco of a comprohansive PRA, Inte rvenors do not believe one can reliably conclude that a CRBR CDA is rot credible, ar.d withcut an adeqaate data base, inclutling test results , one is unlikely to have an adequate PRA.
4 Interrogatory l
1(b)-15 Identify the page number arrl, if approgriate, secticn of the doctments specified in NRDC's "New Information Relevant to Intervenors' Ccntantions", attached to the March 12,' 1982 letter to Staff and Applicants' counsel from NRDC colmsel, at pages 2 and 3, relating to former Centantion 2, now Centantion 1, tpon which you interzl to rely in stppcrting a position regarding Ccntention 1 in this Iroceeding. Specify to which stbpart of (bntention 1 each referarce relates, arti irdicate how you ccnterd that the referarce stpports that stbecmtention.
Response
Inte rvenors are unable to locate the March 12, 1982 le tte r.
r Interrogatory
'1(b)-16 Define " established", as that term is used in Contention 1(b)-(4). Set forth with particularity what Applicants ard/or Staff naast show to " establish" that the Applicants' test progrant will be completed prior to the CIBR projected construction coupletica dete.
Response
1 ,
"Establich" means "to chow or settle" or, in this case, "dem ons tra te . " The test results must vet ify the perfo?.ateince of the uguipment being tested. ,
.Cn71124 TION 2 GENEiWL EMTORY -
Does tWDC contard thet Staff nost analyze all CIA scenarios and their -MMmes for purcosos of licen-3ing the C/BR .ud
, 6wrzstcatirg that the radlological soucce ter:a for t.he CIER would result in ptential hazarde rot exceeded ley those frca any acci$ce;t considered credible? If the enswer is yes, specify tim bases, including supporting data uoan thich NRUC relies, for so corcluding. If the answer is ru, itdicate what hRDC centerrh ths .
criteria should be fcc detern;ining what CIRs ani their consecpstres should be analyzed; specify the bases for selecting the criteria.
. Response No. The criterion and its basis was presented in our LWA-1 l testimony.
CONTENTION 2 ( f )
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Response
Contention 2(f) is hereby withdrawn and consequently no responses to contention 2 (f) Interrogatories are given.
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4 CONTENTION 2 (g)
Response
contention 2(g) is hereby withdrawn and consequently no re sponses to contention 2(g) Interroga tories are given, CCNTENTION 2 (h )
l Reppanse contcystion 2(h) is hereby withdrawn and consequently no rc6ponses to contention 2 (h) Interroga torie s c.re given .
CONTENTION 3(a) ,
_Interroegg 3fa)-1 Idar.tify the emlytic methodology 4tich RT believrn '
we.c teilized in the Pramussen Repcrt, MSH-1403.
Resp 3nse Prcta'of listic Risk Assessment.- <
Inte rrogatory 3(a)-2 Describe the amlytic methcdology whidt tRDC believes was utilized in WuE-1400, in NRDC's own words. Do rot answer this questicn by refemrce or citation to another doctment.
Response
In PRA, accident sequenc es (event trees) are characterized with the obj ective of identif ying the most signi ficant accident sequ enc es . Probabilities are assigned to elements in the event j trees (i .e . system f ailure rates) a nd the se a re s ummed by appropriate algebraic techniques, and fault tree analyses. The consequences of various accident sequences are analyzed and grouped into specific release categories. The probabilities ard
4 consequenc es are then combined to provide an overall risk a s se ssment . See IRSH-1400 Main Report, pp. 41-52.
Interrogitory 3(a)-3 Define "CER accidet possibilities," as that tarm is used in Concention 3(a). Set forth the be.ses for 1RDC's definiticn.
Response
Abnormal Clizch River Breeder Reactor eve *1t sequences that result in the potential f or harm. (See also Response to 3(b)-1 below.)
In_t3][rogatory 3(a)-4 List all CRBR accidet possibilities dtich EDC l ccnteMc have greater frecuencf and/or ccnsegaerce than the accidet scenarios amlyzed by Applicants ard the Staff. Provido l
the specific f requancies (ce range of freqmncies), ard the l specific mnsegasx:es (or range of cocsequences) fcr each accidet
! possibility listed. Provide the basis for each accidet l possibility, by listing all do:tments dtich support the anser to
! this interrogatcry.
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Response
Inte rvenors have no such list . Contention 3 contends that one of the purposes of PRA is to identify such events.
l Interrogatory 3(a)-5 To the extent rot ircludei in your anser to Interrogatcary 3(a)-4 above, list all speci fic accidet possibilities not amlyzed by Applicants ard/or the Staff which have gruater freg2ency or ccnseq2erces than those analyzed by the Applicants ard the Staff, which EDC contenis must be aralyzed as part of the CER review.
Response
See response to 3(a)-4 above.
f
^
- v. -
as
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Interrogatory ,
3(a)-6 Set forth the a:ceptarce criteria, empirical &ta, tests, resear&, a other f actcra whidt NRDC catterds must be utilized by the Staff to determine which CRBR accident . . .
pcesibilities must be analyzed by the Staff.
Response s .,
. t Inter tonors have riot de.veloped such criteria, etc. It is not Interver.crs responsibi lity to do so. -
Interrogatorg ,
3(a)-7 I. int the specific refamnce An= ants Witich provide the buis for NOC#s contention
- hat the criteria, empirical data, -
tests, etc. identified in the anser to interngatory 3(a)-6 must s be utilizal to chterudne thn C'ER mcidst pseibilitf.es.
Response
- See response to 3 (a )-G abov9. , ,
Interrogatory 3(a)-8 Define, " sufficient attention", as that term is ussi by.
- Contenticn 3(a). Set forth the haaaa for NRDC 's definition.
i i 'Respon se Inte rvenor s' basic point is that without conducting a p e n.
comprehensive PRA, one cannot have confidence that CDAs are ,
J outside the DBA envelope.
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i CONTENTION 3(b) ( :
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Interrogatory 3(b)-1 Define, " accident initiators," "sequerres," " events,"
ard "spectrta," as those terms are usel in Ccntention 3(b). Set .,.
fath the bases for 1RIr 's definitiaus.
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Respon se
-" Accident initiators" are the beginning or commencement of a potentially damaging event of a type that one would prefer to avoid " sequences" implies the consequences following the initiation of anievent; " events" are occurrences. The basis f or l s 1
i these definitions are ccamon English language usage as set for th in Engligh' dictionaries such as Webster's New Collegiate Dict iona ry.
s Inte rrogatory 3(b)-2 Define, " credible," as that term is usel in Contention 3(b). Set forth the hamaa for BRDC 's definition.
Response
As defined in our LWA-1 testimony.
Interrogatory 3(b)-3 Set fcrth the aralytical methcdology criteria, empirical data, tests, resear&, cr other f actcrs whicit NRDC conterds should be utilised by the Staff to determine if accidet initiatcrs, seq 2erces and evets are credible. Set forth the bases why these criteria, data, or other factors should be utilized by the Staff.
Respo nse Accepted scientific procedures, principally the scientific method, should be used. It is not Intervenors' responsibility to establish the criteria and empirical data, test s and research program to demonstrate that CDAs in CRBR are rot credible ev en ts .
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_ - - , , _ - , , . ~ . , , . , , . . , , , . ..
- ~ _ _ . . . . .-
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Interrogatory 3(b)-4 Define,' "sufficiently oaqxehesive", as that term is ussi in Contention 3(b). Set forth the haman for tatDC 's ddinition.
Response
"Suf ficiently comprehensive" means " adequately inclusive."
The basis f or this de finition is the same as that given in 3(b) above.
Interrogatory .
3(b)-5 Daseibe dat would, in leDC's judgment, constittee a
- sufficietly compreensive analysis of uma to msure envelopng i
the DBA spectrta for CRBR.
Response
Intervenors did not say a suf ficiently comprehensive analys is of DBAs, rather a suf ficiently comprehensive analysis of accident initiators, e tc.
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Interrogatory i
3(b) -6 Set forth the specific probability limit that NRDC l conterds characterize accident initiatas, sequerces, ani events as j "medible" .
F Respo nse Inte rvenors set no specific probability limits on the initiators, but on the probability of a CDA f rom all potential initiator s. The criterion Intervenors use was set forth in our LWA-1 te stimony.
i Interrogatory 3(b)-7 List all CRBR accident initiators ard sequerces which NRDC ccntenis are not includei in the Staf f's analysis of accident l
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initiators ard segaences in the SER.
Response
Inte rvenors haven' t completed - their analysis of the SER.
l Furthermore, we contend tha due to the potential common mode system f ailures, a comprehensive PRA and common course f ailure
. mode and off acts analyses would be necessary in order to demonstra te , if that were possible, that Ctas are not credible.
Interrogatory i 3(b)-8 Pbr each accident initiator ard sequerre listed in l NRDC's anmer to Interrogatory 3(b)-7, set forth all CIBR systems ard stbsystems Wiich NRDC believes are involved in those initiators ard soglerces.
Response
See response to 3 (b)-7.
Interrogatory 4
3(b) ^ Ptr each accidet initiator an1 sequences listed in NRDC's answsr to Interrogatory 3(b)-7, set fcrth 2RIX:'s urderstardin; of the precise mechanissa ard/or sequerce of events i whids will lead to an accidet.
1
Response
See response to 3 (b)-7.
l Interrogatory 3(b)-10 List each relevant setion ard stbsetion of the 1983 SER for CIBR which NRDC believes inadegantely discusses potential accidet initiators, segamcas ard events.
l Response l
l Inte rvenors have not completed their analysis . of the SER.
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P' t
Interrogatory 3(b)-11 For each section and subsectim of the SER listed in NRDC's answer to Interrogatory 3(b)-lO, discuss in detail why the Staff's analysis is inadegaate, ard set forth specific adaject matters ard items which NRDC contends should be discussel in each secticm.
Response
See response to 3(b)-10.
CONTENTION 3c Interrogatory 3(c)-1 Define "mre melt-thmgh", as that term is used in Contention 3(c). Set forth the bases for NRDC 's definition.
Response
" Core melt-through" means "the penetration of core materials through the bottom of the reactor and guard vessel following a CIA ."
Interroptory 3(c)-2 List all accidents " associated with" mre melt-through.
Response
l For CRBR saf ety and analysis purposes, Intervenors believe 1
it is prudent to assume that any CDA will result in essentially whole core involvement, a full core meltdown and meltthrough of the reactor and guard vessel.
i Interrogatory l
3(c)-3 Define, " loss of core gecmetry", as that term is used in Contention 3(c). Set forth the bases for NRDC 's definiticn.
i L .
Response
" Loss of core geometry" means " irreversible physical movement of fuel and/or fuel cladding."
Interrogatory 3(c)-4 Define, "edium-ccrcrete intamctions", as that term is i usei in Contation 3(c). Set forth the haeaa for NRDC 's definition.
Respo nse "Sodi um-conc re te inte ractions" means " chemical re act ions involving the CRBR coolant ard conc rete -- principally the floor and lower walls of the reactor cavity."
Interrogatory 3(c)-5 List ard describe the mechanisus ad/or sequerce of evets by which soditan-concrets interacticns at CIER may result.
Set forth the bases fcr MtDC's answer.
Respo nse These are generally described in the SER, Appendix A.
l Interrogatory 3(c)-6 List ad describe the auchanisms ard/cr sequerce of events by which loss of core gecmetry may lead to core meltthrotgh accidents. Set fcrth the bases for NtDC's answer.
Response
Failure to adequately cool the core, i .e . core heat l generation exceeding the heat removal capability of the core, leads to temperatures in the fuel in excess of the melting point. The core melts and f alls or drains to the bottom of the reactor vessel under the force of gravity. The conduction of '
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heat from the molten core to the reactor vessel heats the reactor vessel to a point where it is no longer capable of maintaining its shape under the weight of the core and sodium coolant. See SER Appendix A.
Interrogatory 3(c)-7 List each relevant section ad s@section of the SER whids NRDC contends inadegaately analyzes accidets associatsi with core meltthrotgh following loss of core gecnetry.
Response
Appendix A.
Inte rrogatory 3(c)-8 Fcr each secticn ard stbsection of the SER listed in NRDC's answer to Interrogatcry 3(c)-7, discuss in detail why the Staff's aralysis is iradeg2 ate, ard set fcrth specific s@ ject matters ard items which NRDC ccntends should be discussai in each
! secticn ad s@section.
l l Response Inte rvenor s' analysis of the SER is not complete.
In te rv enors ' primary criticism is with Staf f's use of " realistic" 1
rather than " conservative" or bounding assumptions in assessing the consequences , including the time at which venting might be required, and Staf f's failure to treat the CDA as a confinement system design basis accident.
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Interrogatory 3(c)-9 List each mlevant secticn an! s@section of the SER l which NRDC ccnterds inadequately analymes solitmH:oncrete l intemcticms.
Response
See response to 3(c)-8 above.
Interrogatory 3(c)-lO Ebr each SER secticn ard stsection listed in !@T's answer to Interrogatory 3(c)-9, diseass in detail why the StafI's j aralysis is iradeq2 ate, ard set fcrth specific s@ jet matters ani l items whi& NREC cmtends should be discussel in each !ER section
- ard sWeeticn.
Response
See response to 3(c)-8 above.
i Inte rrogatory 3(c)-ll List the environmental pmmeters (i.e., tempemture) ard characteristic values fcr ead parameter whiFNRIC believes am associated with sodiun-ccncrete intemctions.
Response
I Inte rvenors have not made any irxlependent analyses of these, i but will rely on the PSAR, SER and other documents identi fled by Applicants and Staf f.
Interrogatory 3(c)-12 Set fcrth with particularity the CRBR plant locations which NRDC ccntends that scdiun-concrete interacticns could occur. Fcr ptrp3ses of this interrogatory, the location of such interacticms should be specified by building, elevation, rom, arri ccaponent which, if failei, may lead to sylian-ccmcrete intaracticns.
Response
Inte rvenors are primarily conc erned with the interactions that would take place in the reactor cavity.
J Interrogatory 3(c)-13 In MDC's May 5,1982 response to Interrogatory 3-3.c of the Staff's First Ro.1rd of Discovery, filed on April 15, 1992, MtDC stated that "intervenors hwe not developed at this time spectfic acceptarce criteria, whi& intervencrs centerd must be utilised." Have the citeria now been developed? If so, please provide than alcmg with their h==aa. If rot, please state ten they will be provided.
Response
No. If Intervenors do so, these will be incorporated in their te stimony at the CP hearings.
Interrogatory 3(c)-14 In MtDC's May 5,1982 response to Interrogainry 3-3.e of the Staff's First Round of Discovery, filed on April 15, 1982, MtDC stated that the " probability of a CIA progressing to full core involvsamt ard meltthrotgh is high." Define "high" as usel in this response. What is the basis for this statemerit?
Respo nse For purposes of CRBR saf ety analyses, it is prudent to assume it is 100% although obviously this is taken as a i
conservative bounding assumption. It is Intervenors' understanding that Staff and Applicants are also in agreement in this regard. See SER, Appendix A.
CONTENTION 3 (d)
Interrogatory 3(d)-1 List all himan errors whidi EDC believes will initiate, exacerbate, & interfere with the mitigation of CIER m cidents.
Response
NRDC has no such list . Human errors are known to be a principle cause of nuclear reactor accidents as was indicated in
Inte rvenor s' LR-1 testimony.
4 Interrogatory 3(d)-2 Pbr each haan error listed by NRDC in its answer to '
Interrogatmy 3(d)-1, list all accidets that will be initiate 1, exacertated, or Whose mitigation will be interfered with.
- Response See response to 3(d)-1 above.
Into trogatory 3(d)-3 List all relevant sections ani s2 sections of the SER which NRDC contends irhiately identify ard analyze hunan errce Which may initiate, exacerbate, or interfen with mitigation of CRBR accidents.
Response
Inte rvenors have not completed their review of the SER.
Interrogatory 3(d)-4 FT each section ard s@setien listed in NRDC's answer to Interrogatcry 3(d)-3, discuss in detail why the Staff's analysis is inadeq2 ate, ard set fcrth specific s@ jet matters which IRDC cmterds should be discussed in each SER secticn ard subsection.
Response
See response to 3(d)-3 above.
Inte rrogatory 3(d)-5 Define "aralyze", as that term is usal in Contention 3 (d ). Set forth the bases for NRIE 's definition.
Response
" Analyze" means "to study or dete rmine the nature and relationship of the parts of by analysis." Analysis is the separation of a whole into its component partsr an examination of
. . l l
a complex, its elements, and their relations. The basis for 1
these definitions is common English language usage as f ourx1 in ;
Webste r's New Collegiate Dictionary.
1 Interrogatory 3(d)-6 Describe in detail what 15tDC believes the Staff must do in order to adegantely aralyse haan erras whidt may initiate, exacerbate, or interfere with mitigation of OtBR accidents.
Response
A comprehensive PRA and extensive f ailure mode and ef f ects analyses is a minimum requirement.
Inte rrogatory 3(d)-7 Does 15tDC consider human error at CRBR to be more or less of a potential problem than in LMs? Set forth the h for 15tDC's answar.
Response
Inte rvenors do not know, but as an informed estimate ,
Intervenors would assume it to be roughly comparable.
Interrogatory 3(d)-8 Set fcrth the criteria latDC utilizes (or contends should be utilized) in determining
- ether human erra is more or less serious at CRBR *en compared to LMs. Set fath the bases f& NRDC's answer.
Response
Inte rvenors have developed no such criteria.
o l
l ADMISSIONS Admission
- 1. Intervenors have not estimated the probability of occurrence of any Cm initiator for CER.
Response
l Intervenors can neither admit nor deny the statement since "CDA initiator" is not defined. Intervenors admit that Intervenors have not performed an independent PRA of CRBR.
Adnission
- 2. Intervenors have not identifiel any mechanisms for Cm initiation in CRBR not already adiressed cc enveloped in the CER PSAR, and the CRBR SER, NUBEGO)68.
Response
Intervenors can neither admit nor deny the statement as Intervenors have not completed their analysis of the SER.
Adnission
- 3. The Staff has identifiel and evaluated all potential mechanistic Cm initiators for CER.
Response
Intervenors can neither admit nor deny the statement. At one level, Intervenors would admit since all CDAs can be
- classified as due to reduced coolant flow or excessive heat l , generation. At the other extreme, it is humanly impossible to identify every sequence of events that could lead to a CDA.
l L
) Admission .
- 4. The risk fran a CIA at CER is not sigrtificantly different than that at a LWR, as set fcrth in Appendix A of the CRER !ER.
Response
Inte rvenors can neither admit nor deny the statement without more precise understanding of "signi ficantly." In terv enors testified at the LWA-1 henrings that consequenees of a CIR in an LMFBR we re greater than the consequences of LWR CDA (i .e., core j meltdown).
Admissist
- 5. Intervenors do rot have a working knowledge of the m+ar codes described in AppeMix A of the CER SER, whids were utilized by the Staff in its CIA aralyses for CER.
Response
Inte rvenors can neither admit nor deny the statement without knowing what is implied by " working knowledge."
Adnissicn
- 6. Failura nodes ard failure consequerces of GBR systems will be adequately identi fied by the CRBR reliability program, if that program is implemmted in accordarce with the criteria set farth in Apperdix C of the CER SER.
Respo nse ,
Intervenors deny the statement. The criteria are too vague to reach this conclusion.
l l
Admission
- . 7. Applicants have conmitted to incorporating the results of i the CER reliability program into the ongoing desicp aM constrtz
- :ticn of GBR.
l
Response
Inte rvenors admit the statement without admitting as to the adequacy of the program or the commitment.
Adnissicn
- 8. 'Ihe Staff's criteria for the CER reliability grogram (described in Apperdix C of the CMR SER) requires an equipnet performan:e ard qualificaticn test program.
Response
Inte rvenor s admit the sta tement.
Adnissicn
- 9. The Staff's CIA aralyses, as set forth in Apperdix A of the CNR SER, is adecpate for the purposes of licensing CER ccnstructicn.
Respo nse l Inte rvenors object. This calls for a legal conclusion.
l l Adnission
- 10. Analytical mcdels used in the CIA aralyses need not be verified or valichted by comparisan with experimstal chta.
1
Response
Inte rvenors deny the statement. Analytical models that are l
not veri fied or validated should not be relied upon to conduct reactor saf ety analyses for the purpose of demonstrating that licensing requirements are met.
i Adnissicn i 11. Intervenors have not idetified any DBA initiators for .
CRBR not already ideti fied, adiressed, & enveloped by the Staff in the SER, or by the Applicants in the PSAR.
Response
Intervenor s can neither admit nor deny the statement as their analys is of the SER is not comple te.
Adnissicm
- 12. The Staff's aralysis of accidents associated with are melt-through, as describe 1 in Appeniix A of the CMR SER, is adequate for the purposes of licensing CRBR omstrtx: tion. '
Response
Inte rvenors can neither admit nor deny the statement as their analys is of the SER is not comple te.
l l Adnission
- 13. The Staff ccnsidered the impact of luman error in its evaluation cf CER accidents ard its review is adecpate for the purposes of licensing CRBR constructicm.
Response
Inte rvenor s obj ect . This calls for a legal conclusion.
l Adnission i 14. The long term rates of penetraticm of sodiua into concrete
! in all experiments relevant to '1hermal 14trgin Beyond Design Basis
("TM3IB") oxditicms are tounded by a rate of 0.2 in./heur.
Response
Intervenors can neither admit nor deny the statement since we have no bas is of knowing what is meant by "long term" nor do we have access to all experiments.
i Adnission
- 15. Urder the coniiticms existing af ter reactor vessel
penetraticn, a postulated one inch per hour penetration rate of sodium ani core debris into concrete is a reasonable typer bourd to the experimental data.
Response
Inte rvenors deny the statement. See SER Appendix A, Attachment 1.
Adnissicn
- 16. In the event of an accident in which the core detris ard sodiun penetrate the inttom of the vessel, the minimm time for the sodita to boil dry in the reactor carity is expected to be in the rarx3e of 70 to 130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br />.
Respon se Inte rvenors admit that this appears to be a reasonable assumption based on our preliminary review.
Adnissicn
- 17. The reactor cavity ard pipemy cell liners can be expected to renain intact urder T!eDB corditicns fcr at least 50 ard 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> respectively.
Response
Intervenors can neither admit nor deny the statement. We have rot analyzed this as yet.
l
(
l Adnission
- 18. It is feasible to develop criteria for venting the contairment throtgh the cleantp system such that protection frca
- over-presstre or hydrogen btrning within containment will be l
ensured urder T!eDB corditicns, ard the guidelines of 10 C.F.R.100 will rut be exceeded, l
l
Response
Inte rvenor s deny the statement if the question ref ers to the present CRBR containment. It is the Intervenors' pos ition that
the CRBR containment design basis should be a CDA. Under these conditions 10 C.F.R.100 is not met. See our LR-1 Te stimony and Findings .
A&ission
- 19. 'Ihe feasibility of designing a satisfactory contaiment vent
! cleantp system is established by the PF'IP experiarce ard the amlysis ard testing directly related to the CRBR system.
Response
Inte rvenor s deny the sta tement. FFTF was not licensed arri it is 1/3 smaller than CRBR and on a much larger site.
A&ission 20 . The CAGCD code provides useful guidarce fcr determining the pressures ard temperatures developed in the contairnest building on the time-scale of interest in a vessel melt-through accident.
Response
Inte rvenor s admit the sta tement without admitting the adequacy of the guidance in any particular application.
A&issicn
- 21. !EDC has not denonstrated by doctmented engineering aralysis that CIRs should be considered IBAs.
Response
Inte rvenors deny the statement. We did so in the L R -1
- Hearing. It is no ted , howeve r , that the B oa rd f ou nd that no l
party proved or disproved that a CDA is outside the DBA envelope.
- l I
Admission
- 22. ISDC's engireering aralyses, in Wi& it denanstrated tha CIAs should be ccmsidered IBAs, is rot doctmettet.
Response
Intervenor s deny the statement. See response to 21 above.
i Admission
- 23. IRDC has not demonstrated by &cumented engineering aralysis that CIRs occurerce will result in failure of the ccntairunent systems.
Response
Inte rvenors can neither admit nor deny the statement. We do not under stand the admission. Beyond what we presented at the LWA-1 hearings , NRDC's case will be presented at the CF hearings.
Adnission
- 34. IBDC's engineering aralyses, in Wi& it denenstrates tha CIAs cccurrerce will result in failure of the centainnett systen, is rot da:unented.
Response
Inte rvenors can neither admit nor deny the statement. See response to 23 above.
1 Admission
- 25. 'Ihe Staff's aralysis of CIAs is fully documented in the CIBR !ER, an1 the stppcrting refereroe doctuelt NUREGNR-3234.
Response
Inte rvenors can neither admit nor deny the statement.
NUREG/CR-3224 has not been made available to us and we have not completed our review of the SER.
A&nission
- 26. 'Ihe bases fbr the staff's conclusicms with regard to CIA consequerces are fully doctamtal.
Response
Inte rvenors deny the statement. There are many compute r modeling assumptions that are not documented in the SER.
Adnission
- 27. Ihysically reasornble mateling of CA sequeces arri phettanena do rot result in consequerres that would fail the ccntairamt systems.
Response
Inte rvenors deny the sta tement. Human error is physically reasonable and human error can lead to containment f ailure.
Adnission
- 28. EDC has no doctanented,hI ysically reasornble matels of CIA secperces arri phenonera that have bem shown to result in j ccnsecpences that will fail the CRBR contairment systens.
l l
Response
Inte rvenors admit the statement, however our case will be
, presented in our te stimony at the CP hearing.
I Adnissicn
- 29. EDC has not perfcrmed any evaluation of the available reliability chta for the important safety systems for CER.
l l Response l
Inte rvenors deny the statement. Inte rvenors have evaluated CRB RP-1.
i I
A i
1 Achission j 30. MIDC's evaluation of the arailable reliability &ta fx the important safety systems in the CMR is tot doctamented.
Response
Inte rvenor s admit the statement. See response to 28 above.
Admissicm l- 31. NtDC has not identiflel ard doctanented any errors in the Staff's evaluation of the reliability &ta for the impatant safety
! systems for CRBR.
Response
Inte rvenors deny the statement. Inte rvenors did this in the LR-1 proceeding.
A&issicm
- 32. MDC has not idetified ard documented any errors in the Staff's oraluation of the potential fx CIRs at CER as discussed in the CRBR SER.
Response
Inte rvenor s admit the statement. However, Inte rvenors' analysis of the SER is incomplete. When this analysis is completed Inte rvenor s' case will be presented as part of their CP hearing testimeny.
l Admission
- 33. NtDC has not identifiel ard doctanented any errors in the Staff's evaluation of the lose-of-flow without scram event presented in the CER SER ard its stpporting docunent NUMG/CR-
! 3226.
l l
l t
c 4-.
4'
_34
~
Response
Inte rvenors admit the sta tement. Howev er, Inte rvenor s' analysis of the SER is incomplete and we have not been provided NUREG/C R-3224. When this analysis is completed, Inte rvenor s' case will be presented as part of their CP hearing te stimony.
i A&ission
- 34. leDC has not identifiel ard dcctmented any errors in the Staff's evaluation of the transiest overpoter without scram event presented in the CER ER ard its stpporting doctanent NUEG/Clk 3224.
Response
Inte rvenors admit the statement. However, Inte rvenor s' analys is of the SER is incomplete and we have not been provided NUREG/C R-3224. When thic analysis is completed, Inte rvenor s' case will be presented as part of their CP hearing te st imony .
Adnission
- 35. ImDC has not identifisi ard doctmented any errors in the Staff's oraluation of the protected loss-of-heat-sink presental in the CER 2R aid its stpprting doctanent NUIEG/CR-3224.
Response
Inte rvenors admit the statement. However, Inte rvenor s' i
analys is of the SER is incomplete and we have not been provided NUREG/CR-3224. When this analysis is completed, I nte rvenor s' case will be presented as part of their CP hearing testimony.
Adnissicn
- 36. The Staff's evaluation of the potential fcr CIAs in the i CER presettel in Chapter 15 ard Appendix A of the CER SER, l
l i.
,-,--,.n., - - , , .,n. . - - - - - . , . - , - - - - , - , - , - - , , - - .--,-, , , -- - - -
e-styports the conclusion that Cms should be considered outside the design basis spectrum of accidents.
. Response
< Inte rvenors deny the statement. Inte rvenors believe Chapte r 15 provides inadequate a upport f or auch a conclusion.
t 1
Admission
! 37. The Staff's evaluation of the consequences of the lose-of-flow without scram event presente1 in @.1x A of the CIER 2R '
an1 the referarce document NUIEG/CR-3224, stpport the conclusion that highly energetic consequerces from this evett are very unlileely.
Response
Inte rvenors deny the statement. Inte rvenors believe Chapte r 15 provides inadequate support f or such a conclusion. We have not been provided NUREG/CR-3224 and cannot comment as to its
. c on ten t .
i Admission
! 38. 'Ihe Staff's evaluation of the lose-of-flos without scram evet presente1 in Appendix A of the CIER SER, an1 the reference document NUIEG/CR-3224, stpport the conclusion that physically reamrable analyses of Cms do not predtce mergetim that will yield failure of the reactor vessel closure head.
Response
Intervenors deny the statement. Inte rvenor s believe Chapte r 15 provides inadequate support f or such a conclusion. We have not been provided NUREG/CR-3224 and cannot comment as to its c on tent .
Admission l
- 39. The Staf f's evaluation of the Cm events desaibst in the
. _ _ _ , . . . _ . , _ _ ~ _ , _ . . _ . . - - _ , . -
. i GBR SER, ard the reference doceent NUIEC/CR-3224, adequately represent the range of consequences that can be expected fran CIRs
~
in the CIBR.
Response
Intervenors deny the statement. The Staff fails'to conservatively analyze CDAs and their' consequences. We have not been provided NUREG/CR-3224 and cannot comment as to its content.
I Admission
- 40. ISDC has not identified ard documented any errors in the Staff's evaluation of the range of consequences that can be expected fran (Ins in the CRBR, as 1: resented in the CRBR SER ard the refererne doceent NUREG/CR-3224.
Response
Intervenors admit the statement. However, Intervenors' analysis of the SER is incomplete and they have not been provided NUREG/CR-3 224. When this analysis is completed, Intervenors' case will be presented as part of their CP hearing testimony.
Admission
- 41. 'Ihe CIA evaluation methodology used by the Staff utilizes
, physical reasonirq ard engineering judgment to augment its i assessments of results fra computer code calculations.
Response
Intervenors cannot admit nor deny this statement, but admit this is a reasonable inference.
Admission
- 42. CIA evaluation methodology should not be based on a purely mechanical applicaticm of computer codes to predict the cc gences of CIAs without resort to engineering judgment.
e v- --
--n, +-w--- .- ,- +g , - n. , _r - , . , . - - - ____.__.,__
A l
Response
Intervenors admit the statement.
Respectful submitted ,
f
- ./6 yv'1 C &
Bar ra A. Finamore S. acob Scherr M tural Resources Def ense Council, I nc .
1725 I Street, NW, #600 Washington, D.C. 20006 (202) 223-8210 Dated: April 22, 1983 f
1 i-1
Om nEU' April 217 1983 UNITED STATES GF AMERICA NUCLEAR REGULATORY COMiff6Sf6N22 P1 :55 ATOMIC SAFETY AND LICENSING BOARD
~
Marshall E. Miller, Chairman,[NcyBefore Adminstrative Judgess. ,[ g 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:
- 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 interrogat.ories.
- 2. The foregoing answers are true and correct to the best of my knowledge and belief.
be Dr. Thomas B. Cochran Subscribed and sworn to before me this 21st day of April 1983.
YdDNotary GwPublic WYs Mr Cummission Evpires py L, ; .
N s
~
p.
. i' .
i
, l CERTIFICATE OF SERVIC I hereby certify that copies of RESPONSE OF INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC.*ghfiDpTipl2 SFSRS CLUB TO i APPLICANTS' NINTH SET OF INTERROGATORIES DATED APRIL 8, 1983; RESPONSE.OF INTERVENORS TO NRC 3TAFF FIRST SET OF CONSTRUCTION ,
PERMIT INTERROGATORIES AND REQUESTS FOR ADMISSIONS;TO NATURAL '
RESOURCES DEFENSE COUNCIL, INC. AND THE' SIERRAICLUB',' CONCERNING
- CONTENTION 10, DATED APRIL 8, 1983; RESPONSE "Of INTERVENORS TO i NRC STAFF FIRST SET OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUESTS FOR ADMISSIONS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB, CONCERNING CONTENTION ll(A) (ALARA),
DATED APRIL 8, 1983; RESPONSE OF INTERVENORS TO NRC STAFF FIRST SET OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUESTS FOR ADMISSIONS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB CONCERNING CONTENTION 9 (EMERGENCY PREPAREDNESS),
DATED APRIL 8, 1983; and RESPONSE OF INTERVENORS TO NRC STAFF FIRST SET OF CONSTRUCTION PERMIT INTERROGATORIES AND REQUESTS FOR
- a. ADMISSIONS TO NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE i:
. SIERRA CLUB CONCERNING CONTENTIONS 1, 2, AND 3 (HCDAs) DATED APRIL 8, 1983 were served this 22nd 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 l
'U.S. Nuclear Regulatory Commission 4350 East West Highway, 4th floor Bethesda, MD 20014 I
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Stuart Treby, Esq.
Geary S. Mizuno, Esq.
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Office of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road l-Bethesda, MD 20014 l
t
- Indicates hand delivery.
. _ - _= .. . .- - -
e f
s Certificate of Service - 2
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555
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3AA dw
. Jacob Scherr 1