ML20073P260

Response to 830408 Ninth Set of Interrogatories.Related Correspondence

ML20073P260
Person / Time
Site:	Clinch River
Issue date:	04/22/1983
From:	Scherr S National Resources Defense Council, Sierra Club
To:	JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
References
NUDOCS 8304250092
Download: ML20073P260 (31)

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'83 APR 22 P1 :54 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 ' NINTH SET OF INTERROGATORIES DATED APRIL 8, 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 Def ense Council, I nc . and the Sierra Club, hereby respond to Applicants' Ninth Set of i

Interrogatories, dated April 8, 1983.

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General Answers (a) & (b) Documents other than the PSAR and SER are identified below in the direct response to each question.

(c) - Thomas B. Cochran is - the primary Intervenor employee who provided the answer to each question.

(d) Intervenors have not yet identified any such experts.

CONTENTIONS 1, 2 and 3 Interrogatory

1. Identify arti describe in detail all statements, analyses ani conclusions in Chapter 15 of the PSMt with which Intervenors disagree. 'Ihe response to this interrogatory must irclude a detallai description T explanation of all bases for Intervenors' disagreement.

a. As to each such statement, analysis or conclusion, describe all analyses perfcrmed by Intervenors which stpport Intervenors' positicrt,

b. Identify all doctments sich stpport Intervenors' response to this interrogatcry.

Response

Inte rvenor s' basic position with regard to Applicants' CRBR .

accident analysis regarding Contentions 1, 2 and 3 are set forth i

l in our LWA-1 Testimony, Proposed Findings of Fact and Contentions of Law, and in the Contentions themselves. Intervenors have not undertaken a line-by-line analysis of Chapter 15 of the PSAR and

! do not intend to conduct such a research effort, but will continue to rely on the PSAR as a ref erence document as the need arises.

rh Interrogatory

2. Identify all statements, analyses ard cmclusions in Chapter 15 of the SER with which Intervenors disagree. The respmse to this interrogatcry must irclude a detailed deseiption or explanation of all hamaa for Intervances' disagreement.

. a. As to each such statement, analysis or conclusicri, describe all analyses performed _ by Intervances which support Intervenors' position.

b. Identify all doctaments diich stpport Intervenors' respmse to this interrogatzy.

Response

See the Response to Interrogatory 1 above, substituting "SE R" f or "PSAR" .

Inte rrogatory

3. State whether Intervenors agree that all ptential reactor accidets involving the core must involve either redtred heat removal or excessive heat generaticn or both.

a. If Intervencrs disagree, describe in detail the basis for the disagreenent ard provide a list of all additional conditicris other than redtred heat renoval er excessive heat generation involved in all potential reactor accidents related to the core.

b. Fx each categcry of condition identified alove, describe the physical Irirciples which lead Intervenors to corclude that the condition is involvei in all potential reactor accidents related to the core,

c. Identify all doctanents dicit stpport Intervenors' respmse to this interrogatcry.

Response

In the context of Contentions 1, 2, and 3, the answer is yes.

Inte rrogatory

4. State whether Intervenors agree that reduced whole core heat raroval could occur in only two ways: (1) reduced primary coolant flow throtr3h the core; ard/or (2) ircreased primary coolant tenperature at the core inlet. If Intervenors disagree, describe in detail the tasis for the disagreement irrluding a description of any additional causes of redtred sole core heat renoval.

a. Identify all doctanents which suptort Intervenors' response to this interrogatcry.

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Response

Intervenors agree with this statement.

Inte rroga tory

5. State whether Intervenors agree that the bourding loss of punping power design basis accidet (IBA) is the simultaneous failure of all three pmp motors ard the stbeeq2ent coastdom of all three primary punps.

a. If Intervenors disagree, describe in detail the basis for the disagreenent,

b. If Intervenors disagree, describe in detail the bourding loss of punping power IBA.

c. Identify all docunents which stpport Intervenors' respcmse to this interrogatory.

Response

Intervenors have no basis for disagreeing with Applicants' use of this event to define what Applicants refer to as the "tounding loss of pumping power DBA." Obviously, more severe events can occur; e.g. station blackout while operating on two loops, or simultaneous failure of all three pump motors and seizure of one pump.

Inte rrogatory

6. Describe in detail any failure mcde of which Intervenors are aware whidt would result in the simultaneous seizure of more than one punp in the primary heat transport system.

a. As to each failure mcde described above, state whether Intervenors believe that such failure node is credible.

b. As to any failure made which Intervencrs believe is credible, describe in detail any amlysis, testing, or operating experierre, ce any other chta which supports Intervences' position that such failure made is credible.

c. Identify all dccuments which stpport Intervenors' respcnse to this interrogatory.

Response

One such failure mode would the sabotage of two pumpe.

a. Because . the Staf f has a circular definition of credible (See Intervenors' Findings of Fact), Intervenors are unable to answer this query. We are not aware of any quantitative risk assessment 'of this failure mode.

"a."

b.-c. See above.

In te rroga tory

7. State whether Intervenors agree that the CRBBP desi@ basis leak represents loss of a very small fraction of the total core flow arrl thus does not represent a sigrtificant reduction of heat removal capability,

a. If Intervenors disagree, describe in detail the basis for the disagreement.

b. Identify all dcctanents sich support Intervenors' respasse to this interrogatcry.

Response

Intervenors have no basis for disagreeing with this statement at this time.

Inte rrogatory

8. State whether Intervenors agree that the bounding DBA for sole core heat renoval d2e to increased core inlet tancerature is the complete and instantaneous stopgage of all heat removal from one intermediate heat exdianger (IHX) while the reactcr is operating at full power,

a. If Intervenors disagree, describe in detail the basis

. for the disagreenent, including a description of any alternative l desip basis accident due to ircreased core inlet temperature.

I b. As to any alternative design basis accident identified by Intervenors, state whether Intervenors believe such desigrt insis accident is credible arri identify any analyses, tests, prior experience or any other data Wich stpport Intervenors' position that such design basis accident is credible.

c. State whether Intervenors agree that instantaneo2s stoppage of intermediate heat transport systen (IHTS) sodium ficw is not physically possible. If Intervenors disagree, describe in detail the basis for the disagreenent.

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d. Identify all doctments which stpport Intervenors' respcmse to this interrogatzy.

Response

Intervenors have no basis for agreeing or disagreeing with this statement at this time.

Inte rrogatory

9. State whether Intervenora agree that simultaneous mechanical failure of ccaponents (ptanps, pipes ard steam gemratcrs) in more then one IHTS loop are not credible.

a. If Intervences disagree, describe in detail the basis for the aisagreement.

b. If Intervenors disagree, descibe any aralyses, tests, prix experierre oc any other data which stpport Intervenors' position that simultaneous mechanical failures of --- -wnts in more than one IHTS loop are credible.

c. Identify all dcctanents which stpport Intervenors' respcnse to this interrogatcry.

Response

Without a better definition of what Applicants mean by the word "c redible", Intervenors cannot answer this question.

Inte rrogatory

10. State whether Intervenors agree that emessive heat generation requires a reactivity insertion to the reactor,

a. If Intervenors disagree, describe in detail the basis for the disagreement, including a description of any other causes of emessive heat generaticn.

b. Identify all dcctments which stpprt Intervenors' response to this interrogatTy.

Response

Intervenors agree with this statement.

Inte rrogatory

11. State whether Intervenors agree that reactivity can be inserted in only two significant mys: (1) control red withimwal ani (2) vticn of fuel geanetry.

a. If Intervenors disagree, describe in detail the basis for the disagressent, including a description of all other ways in which reactivity can be inserted.

b. Identify all dcctments which stpport Intervenors' respcuse to this interrogatcry.

Response

Intervenors agree with this statement.

Inte rrogatory

12. State whether Intervenors agree that the bounding design basis accident which envelops all fuel movement resulting in excessive heat generation is the instantaneous inserticn of the maxista possible reactivity frca stbassembly duct compaction.

a. If Intervenors disagree, describe in detail the basis for the disagreement, including a description of any alternative design basis accident enveloping all fuel movement resulting in excessive heat generation,

b. Describe in det. ail all analyses, tests, Irior experierre cr any other chta whidi support Intervencrs' altermtive design basis accident.

c. Identify all documents which stpport Intervenors' respcnse to this interrogatcry.

Response

Inte rvenors have no basis for disagreeing with Applicants' use of this event to de fine what Applicants ref er to as the

" bounding design basis uccident. . ." Intervenors do not know precisely what events " subassembly duct compaction" is meant to encompass.

Interrogatory

13. State whether Intervenors agree that becatse the core fcrmer ring arri fuel assembly ducts are passive devices located inside the rea: tor vessel, human interacticn camot modify cr

( interfere with the behavice of these componsits chring plant

, operaticn.

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a. If Intervenors disagree, describe in detail the basis for the disagreement, including the ways in which htman interaction could modidfy or interfere with the behavior of these components.

b. Identify all doctments whidt stpport Intervenors' response to this interrogatory.

Response

Intervenors disagree with this statement. A CDA could be initiated through human error during reactor operation which could modi fy f uel asssembly ducts.

f Interrogatory

14. State whether Intervenors agree that all core-related accidents result from m imhnlarce betwem heat removal ard heat generaticn.

a. If Intervenors disagree, describe in detail the insis for the disagreement, including a description of any other ways in which accidents relating to the core could be ca2 sed,

b. Describe in detail any analyses, tests, prior experience or any other data Wiich stpport Intervenors' alternative causes of core-related accidents.

c. Identify all doctments diich stpport Intervenors' respcnse to this interrogatcry.

Response

i See response to Interrogatory 3 above.

I Inte rroga tory i 15. Idetify ad describe all initiators, sequerces, ad/or evets not enveloped by Applicants' design basis accidents that Intervenors believe are: 1) credible ard 2) could lead to reduced heat removal from the core x excess heat geeraticn in the core.

a. Describe in detail the basis for any additioral i initiators, sequeroes, and/cr events which Intervences believe are credible ard which cauld lead to reduced heat removal frts the core or excess heat generaticn in the core.

b. As to each initiator, sequerce, or event described atove, state the basis for Intervencrs' belief that such initiator, i sequerce or event is credible.

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c. Identify ani describe all analyses, tests, Irior experierce er any other &ta whis stpport Intervenxs' position '

that su& a&5itional initiator, sequence, or event is credible.

, d. Identify all doctments whi& stpport Intervenzs' response to this ' interrogatory.

Response

Cms ,

a -d. Initiators of Cms are described in numerous documents by Applicants, Staff and other authors , e.g. CRBRP-1, and Walter and Reynolds, Fast Breeder Reactors.

In terroga tory

16. State whether Intervenors agree that the following four (4) categories of design features are neessary ani suf ficient to prevent initiaticn of an hypothetical core disrtptive accident (IEM): (1) the reactor shutdown systems; (2) the shutdown heat removal systems; (3) means to prevent primary heat transsort system (PHTS) pipe leaks larger than the design basis leak; ani (4) feattres to prevent local imbalance between heat generation ani heat removal.

a. If Intervenors disagree, deseibe in detail the basis for the disagreenent. , including a description of any additional or altemative desigrt features which Intervenors believe are necessary to prevent initiation of an HCm.

b. As to each design feature dessibed above, deselbe in detail the HCm initiator whi& the particular feature is meant to prevent.

c. Identify ani describe any aralyses, tests, prior experierce & any other &ta which stpport Intervenzs' response to this interrogatory.

d. Identify all docunents which stpport Intervenors' respcnse to this interrogatmy.

Response

Iritervenors disagree with this statement.

a.-d. See Intervenors' LWA-1 Testimony and Finding of Fact.

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Inte rrogatory

17. State whether Intervenors agree that the reactor sNtdom systems catsist of two redandant, diverse, .irdeperdent,-fast-acting shutdom systems,

a. If Intervenors believe that the reactor sMtdom systems are rot re&2ndant, describe in detail the basis for Intervenors' belief,

b. If Intervenors believe that the reactor sMtdom systems are rot diverse, describe in detail the basis for Intervances' belief.

c. If Intervenors believe that the reactor sMtdom systems are rot indeperdent, describe in detail the basis for Intervences' belief.

d. If Intervenors belive that the reactor sMtdem systems are rot fast acting, describe in detail the basis for Intervenzs' belief.

e. Describe in detail any criticisne which Intervenrrs have of the reactor shutdom systems designed for Clinch River.

f. Identify all docments which etpport Intervenorr,'

respasse to this interrogatcry.

Response

Intervenors agree that there are two fast-actir.g shutdown systems that have elements of redundancy, diversity and ind epe nd enc e.

In te rrogatory

18. State whether Intervenors agree that eitbar of the reactor

. shutdown systems is capable of shutting down the raactcr and

" preventing HQA initiaticm, assming any single flilure within the

. operable system (including the asseption that the nest reactive

' control rod in the operable system does not insert.)

a. If Intervencrs disagree, describe in detail the basis for the disagreement.

b. Identify all decemts which stpport Intervenors' response to this interrogatory.

Response

l Intervenors agree that these are designed to meet the single f ailure criterion. Intervenors have no basis for concluding that sys tems will ope ra te as inte nd ed .

- -_ _ - a _ _ _ .

0 Inte rrogato ry

19. State whether Intervenors agree that the reactor sMtdom systems rely on proven technology.

a. If Intervenors disagree, describe in detail the basis for the disagreenent, includirsg a description of the technology diich Intervenors believe is not already goven.

b. Identify all docunents which support Intervenas' response to this interrogatory.

Response

Intervenors disagree with this statement. The history of reactor shutdown systems is insuf ficient to " prove" that they will meet their intended performance goals.

In te rrogatory

20. State whether Intervenors agree that any one of the four overall SNtdown Heat Renoval Systems pths has the capability to irrlependently reject the reactor decay heat,

a. If Intervenas disagree, describe in detail the basis for the disagreenent.

b. Identify all do:unents dtich support Intervenors' respcnse to this intarrogatay.

Response

Inte rvenors agree that this is a design objective within the perf ormance limits of Applicants' DBA envelope definition.

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Inte rrogatory

21. State whether Intervenors agree that anyone of the heat transpxt systen pths in conjurz: tion with the ncrmal feedwater system or AFN5 adequately removes rea: tor decay heat without the use fx operata action.

a. If Intervenors disagree, describe in detail the bssis l

for the disagreenent.

b. Identify all docunents whidt stprort Intervenors' respcnse to this interrogatay.

Response

Intervenors do not know, but presume this is the design obj ective .

Interrogatory

22. State Whether Intervenors agree that the thermal centers of the reactz, the IHXs, the steam generators, ard the protected air cooled oortlensers (PAG:s) are at successively increasing elevaticns.

a. If Intervenors disagree, describe in detail the basis for the disagreemet,

b. Identify all decments Wiich stpport Intervenors' respcnse to this interrogatay.

Response

Intervenors agree with this statement.

In te rroga tory

23. State whether Intervenors agree that by placing thermal cetors of the heat exchanging canpcnents at sucx:essively increasing elevations in the plant, the three heat transport system gaths can renove shutdom decay heat using retural circulation.

a. If Intervenors disagree, describe in detail the basis for the disagreenent, including a detalla3 descripticn of the hysical Irinciples which muld preclude natural circulaticn.

Response

Intervenors 'selieve this is a necessary but not a suf ficient co ndition.

Inte rrogatory

24. State whether Intervenors agree that by ming the natural circulation capability, along with the turbine drive auxiliary feed water pap, tattery-powered instruentaticn ard cntrol, the shutdom heat removal system capability can be maintained even in the event of loss of all offaite power ard loss of all three on-site diesel geeratcrs.

a. If Intervenors disagree, describe in detail the basis for the disagreenent.

b. Identify all docments which stpport Intervenors' respasse to this interrogatory.

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Response

Intervenors agree that this is the design intent. However, it has not been demonstrated.

Inte rrogatory

25. State whether Intervenors agree that due to the high boiling point of sodia, the use of guard vessels arouni the primary heat transport system caponents ard elevated piping cutside the guard vessels, the Primary Heat Transport Systeam (PHrS) desip precludes loss of coolant from the core as the result of PHTS leaks an1 assures shutdows cooling even if leaks should occur,

a. If Intervenors disagree, describe in detail the basis for the disagreenent.

b. Identify all doctments which support Intervenors' respcnse to this interrogatmy.

Response

Inte rvenors disagree with this statement. " Preclude" means "make impossible" . As Applicants' own witnesses testi fled at the LWA-1 hearings, "anything is possible" if you discount the probability of its occurence.

Inte rrogatory

26. State whether Intervenors agree that the core inlet desip precludes the occurrerce of an accident similar to that t#ti&

occurred at Fermi.

a. If Intervenors disagree, describe in detail the basis for the disagreement, including a description of the seq 2erce of events which could lead to a Fermi-type accident at CIBRP.

b. Identify all doctnents whidt stpport Intervenzs'

! response to this interrogatory.

Response

Intervenors disagree with this sta tement. " Preclude" means "make impossible". As Applicants own witnesses te sti fi ed a t the l

LM-1 hea rings , "anything is possible" if you discount the probability of its occurence. .

Inte rrogatory

27. State whether Intervenors agree that the direct heat-renoval system is capable of resoving shutdem heat in the avet the three heat transport system pths are simultanecusly ircapable of removing the shatdom heat.

a. If Interverx>rs disagree, describe in detail the basis for the disagreement.

b. Idetify all dcruments whidt stpport Intervenors' respnse to this interrogatcry.

Response Inte rvenors agree that this is the design intent, assuming .

the re is no common cause f ailure.

Inte rrogatory

28. State diether Intervenors agree that the four shatdom heat rearwal system (SHRS) paths are retbrxhnt, diverse, arri irdeperdent.

a. If Intervenors disagree, describe in detail the basis i for the disagremet that the four SHRS paths are rechrxSant.

b. If Intervenors disagree, describe in detail the basis for the disagreenet that the four SHRS pths are diverse,

c. If Intervenors disagree, describe in detail the basis for the disagreemet that the four SHRS paths are irtleperdent.

d. Identify all dcctaients which s@ port Intervenors' response to this.interrogatcry.

Response

Intervenors agree that the four shutdown heat removal system l

paths have elements of redundancy, diversity and independence.

The three primary loops are not diverse.

- - . - .-.- - . ~ . _ . - - - - - - - . - - - - . _ . . . . - , - - . - - - . . . . - - - - - - - .

_ .- - ~_ . - --

Inte rrogatory

29. State Whether Intervonors agree that becatse the edium coolant is maintained daring operaticm at near atmospheric pressure, there is reduction of the intamal force acting on the PffrS piping, thas rMng the mechanism that could cause a -11 piping flaw to grow to boccme a crack and cause a maall crack to develop into a major leak,

a. If Intervenors disagree, describe in detail the basis for the disagreement. The response to this interrogatory must include a detailes descripticrt of the ways in Which Intervenors believe a do@le-ended pipe rupture could coctr,

b. Identify all documents dtich stpport Intervenors' response to this interrogatzy.

Response

Intervenors disagree with this statement. There is more than one physical phenomenon (or " mechanism") involved in crack growth. See the Harris report cited by Intervenors in our LWA-1 ,

testimony.

Inte rrogatory

30. State Whether Intervenors agree that due to the totx3 ness h

ani dactility of the PffrS stainless steel piping, if a large initial flaw were to exist, there muld not be any aignificant growth of the flaw.

a. If Intervenors disagree, describe in detail the basis for the disagreenent. .

b. Idettify all doctanets which stpport Intervenors' response to this interrogatcry.

1

Response

Intervenors can neither agree nor disagree with this statement, without a precise definition of what Applicants consider " signi fi cant" .

In terroga tory

31. State Whether Intervenors agree that the leak detecticn system monitoring'the FifrS piping an1 the cells in which the piping is located can detect leaks as snall as 100 grams per hour.

a. If Intervenas disagree, describe in detail the basis l

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for the disagreement.

b. Identify all doctments which stpport Intervonors' respcmse to this interrogatory.

Response

Intervenors have no basis for agreeing or disagreeing with i

this statement at this time.

Inte rrogatory

32. . State whether Intervenors agree that if a small leak is not detected aM corrective action taken, the toupiness ard ,

ductility of the stainless steel piping, alcng with the low coolant operating pressttre, would limit the maxista crack length and would not result in a dc@le-endet pipe rtettre.

n. If Intervenza disagres, describe in detail the basis for the disagreement.

b. Identify all doctments Whi& stpport Intervonors' respcmse to this interrogatcry.

Response

Inte rvenors agree that this is the most probable outcome.

. In terroga tory i 33. Idarttify any instarce of which Intervenors are amre of a double-ended pipe rupture in a nuclear power plant using a sodita coolant system.

a. As to any instarce described above, identify the nuclear power plant which experienced a double-ended pipe rupture ard describe the sequerce of events which led to the doWle-erried pipe rupture ard idnther the double-erded pipe rupture resulted in any core damage,

b. Identify all doctments whicit stpport Intervenors' respcnse to this interrogatcry.

Response

Intervenors are not aware of any such instances.

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Inte rrogatory

34. Describe in detail any local imbalarce between heat gmeration ard heat removal whids Intervencrs believe could result in the intiaticm of an HCIA at CRBIP.

a. Identify all doctmetts whi& stpport Intervencrs' response to this interrogatory.

Response

Intervenors have nothing to add, at this time, to the discussions of this subject matter that appear in the PSAR, SE R, SSR ard our LWA-1 Testimony.

In te rroga tory

35. Describe in detail the sequence of events other than an HCIA which Intervencrs believe could dia11enge the ccntairment at CIBRP.

a. As to each sequence of events, describe in detail the controlling parameter (e.g., tanparature, pressure).

b. Identify all doctments which stpport Intervenors' respcnse to this interrogatay.

Respo nse Loss of containment could occur through human intervention, e.g, operating the reactor in a manner not in accordance with proposed operating procedures.

In te rroga tory

36. Describe all local fuel faults which Intervenors believe could propsjate to diole core involvenett.

a. As to each local fuel fault identiftel above, describe in detail any previous experience in whids such a 1cx:al fuel f ault

! progagated to whole core involvemmt.

b. Identify all doctmetts which stpport Intervencrs' response to this interrogatory.

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Response

Inte rvenors have nothing to add, 'at this time, to the discussions of this subject matter that appear in the PSAR, SER, SSR and ' our LR-1 Testimony.  ;

Interrga tory ,

37. . State uhether Inturver.urs agras that the control rcris will L reect la suf ficient the a:d with safficist wrth to aciniece a '

E balarte tetuca heat generatico ced 5a.it rencval. .

a. If Intervences disagre, describ3 in detail the basis fa the dissg utxwt.

I

b. Identify all da:tacnts W.ich scoprt Intervenors' respcnas *:o this interttxptcry.

_Refpottss '

Intervenue agran that this is the design objective. j

In te rroga tcry .

- 38. State whether Intervenors are aware of any initiators, secperces, cr evets rot includal in cr ~eriveloped by Applicants' desicp1 basis acciderits other than HCIAs.

a. Identify all doctments whidt stpport Intervences' 7

response to this interrogatory.

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Response

Intervenors are aware of none.

In te rroga tory j 39. Describe in detail any inadeq2acies in Applicants' analysis of core meltthrotgh following loss of core geometry.

a. Describe any armtlyses, tests, prior experience or any other data of which Intervences are aware which demcnstrate that Applicants' analysis is inadecpate.

b. Identify all doctments which stpport Intervenors' l

respcnse to this interrogatcry.

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Response

Our primary objection, as indicated in our LWA-1 testimony, is Applicants' f ailure to treat CDAs as a containment design

- basis accident and, consequently, Applicants' use of "best

- es tima te" rather than conservative assumptions in the analysis.

Inta rroga tory ,

40. Describe in dutail any inadequacios in Applicants' analyasis of the says in whidt huaan error can initiate, exacertate,

. or inberfere with the mitigaticn of CERP accidents.

a. Ider.tify ard describe in detail all hunan errcrs which can initiate accidenta at CmRP ard which hwe not been adequately analyzed by Applicants. '

b. ldmtity anl describe in detail all h.immt errcts which l' can exa

erbate accidents at CmaP which have rot bem adeque.tely antlyzed by Applicants.

c. Identify all himan errors which can interfere with the mitigation of accidetts at CmRP w?.idt Applicants have rot adequately amlyceu.

d. Identify all dccunents whidt stpp3rt Intervenors' respcnse to this interrogatcry.

Response

See our LWA-1 testimony.

c In terroga tory

41. Defire the term " reliable data" as used in Intervenors' Contention 1.a.

Response

" Reliable data" means " suitable f actual inf ormation capable of being used to predict meaningf ul usef ul re s ul ts . "

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- Inte rrogatory

42. Defim the term "sufficiently law" as used in Intervenors' Contention 1.a.

Response

Suf ficiently low" means " quantitatively small enough. ,

It terroga tory

43. Identify ard describe all amiyses, statements ard

, corcituicns ccntalnai in 7pdir A of the SER with which Intervenors am in disagreentent. 'Ibe response to this interrogatory must include a detailed description er ext i amtion of all bases for Intervenors' disagreemmt. <

a. As to etch sui smlycir, statament, or ccrclusicn, descri're all amlyses performed by Intervesxrs whidi stpixxt '

Interwmors' peiticn.

b. Metify all dcctmente 4116 stpport Intnrvenors' i res}xnae to this interrogatory.

Respanse I nte rvenor s' basic position with regard to Staf f's CRBR accident analysis regarding Contention 1, 2 and 3 are set forth in our LWA-1 Testimony, and Proposed Findings of Fact and Conclusions of Law arx1 in the Contentions themselves.

Intervenors have not had time to make a line-by-line analysis of l

t Appendix A of the SER and do not intend to conduct such a re sea rch e f f or t, but will continue to rely on it as ref erence document as the need arises.

Inte rrogatory

44. Identify ani describe in detail all amlyses, statements, ani concitmicms ccntainsi in CIERP 3, Vol.1 ani Vol. 2 with which Intervenors are in disagreement. The respnse to this interrogatory must irclude a detailei description cr explamtion of all bases for j Intervmors' disagreement.

a. - As to each such aralysis, statement, or conclusion, describe all analyses perfcrmed by Intervencrs Whidt suppcrt Intervenors' positial.

b. Identify all docments 211ch stpport Intervenors' response to this interrogatcry.

Response

Inte rvenor s' basic position with regard to Applicants' CRBR accident analys is regarding Contention 1, 2 and 3 are set forth in our 'LWA-1 Testimony, Proposed Findings of Fact and Conclusions of Law and in the con tentions themselves. Intervencrs have not [

had time to make a line-by-line analysis of CR9R2 3, Volumes 1 and 2 and do not intenc! to conduct such a research effort, but will continue to rely on CRBRP 3, volumes 1 and 2 au the need i

i ar ise s . ,

Inte rrogatory

45. Identify all mcdels ard comptter codes used by Applicants in their analysis of CIAs ard their consecperr:es which Intervencrs believe have not been adetpately docmented.

a. As to each cceputer code identified above, describe in detail the additional categories of the doctmentation which i Intervencrs believe would be sufficient.

! b. Idattify all dcx:tments which stpport Intervenors' response to this interrogatcry.

Response

Intervenors have not completed their analysis and at this l

time have nothing to add to their LWA-1 testimony in this rega rd .

i Inte rrogato ry

46. Identify all axlels ard computer codes used by Applicants l in their analysis of CIAs ard their consequerces which Intervencrs

- believe have not been adequately verified.

a. Describe in detail the additional experimettal chta

( which Intervenors believe are necessary to verify the nodel or ocmputer codes.

l b. Identify all dcx:tments diich stpport Intervenors'

response to this interrogatory.

1 1

Response l Intervenors have not completed their analysis and at this

~

time have nothing to add to their LWA-1 testimony in this regard.

Inte rrogatory

47. Idetify all acdels ard cceptter codes tred by Applicants ,

in their aralysis cf CDAs and their conseg2eruss Wich Interveacrs believe have not been ade:pately validated.

. a. Describe in detail the additional experimetal chta which Interwnors telieve are ne:essary to validate the models i arx1/or cesputer codes.

Idetify sil documents which stpport Intervences' b.

) response to this interrogatory.

l Response Intervenors have not completed their analysis and at this time have nothing to add to their LNA-1 te stimony in this rega rrL Inte rrogatory

48. Describe in detail the basis for Intervenors' statement in Contaticm 2.f) that " Applicant's and Staff's safety analyses did not establish that the models accurately represent the physical pheremern and prirciples which castrol the resptmse of a CBBR to CIAs" .

a. Describe the precise "litysical phenomena" referred to in Intervencrs' Contattion 2.f).

b. Describe the precise "prirciples" referred to in

( Intervencrs' Ccntention 2.f).

l c. Identify all occtments which stpport Intervenors'

contattion that the models do rot accurately represent the physical phencanna ard prirciples dtich control the response of GBRP to l CIRs.

d. Identify all doctments whidt stpport Intervenors' response to this interrogatzy.

l I

l

Response

Intervenors have not completed their analysis and at .this time have nothing to add to their LM-1 testimony in this rega rd .

Inte rrogatory

49. Idmtify ani describe in detail all input data fcr the ecsputer ma5els ard ca5es used by Applicants whicn Intervenza believe am not adequately dactneented.

a. Describe in detail the additional documentation which l Intervencrs believe is ncessary.

- b. Identify all der'= ants which stpport Incervenors' l response to this interrogatcry.

Response

. Intervenors have not completed their analysis and at this l' time have nothing to add to their LNA-1 testimony in this regard. ,

Inte rrogatory i 50. Describe in detail the asstaptims for the m ar moiels ard codes which Intervances believe are rot adecpately dcctansted.

a. Describe in detail the a5ditional doctmentation which Intervances believe is necessary.

b. Idetify all doctments which stpport Intervenors' response to this interrogatcry.

Response

Intervenors have not completed their analysis and at this i

time have nothing to add to their LWA-1 te stimony in this rega rd.

Inte rrogatory

51. Identify all input data for the canptter solels ard codes used by Applicants which Intervencrs believe are rot adecpateley verifiel,

a. Describe in detail the additional data neessary to verify the input data.

b. Identify all doctanents which stpport Interverors' response to this interrogatay.

Response

.- - . - - - -.,,.m . . , . . . . . . _ . . , - - , _ . , = _ . . _ , _ , . , _ . . . - - . _ , , , - . . . , . _ . -

I l

Intervenors have not completed their analysis and at this time have nothing to add to their LWA-1 testimony in this rega rd .

Inte rrogatorg

^

52. State **.her Intervenxs agree that the coolant bourdary can withstand dynamic lomds equivalet to an mergetic release of 661 M7s.

a. If Inberveiers disagree, deselbe in detail the basis for the disagreemet. 'Ihe answer to this intenogatzy must include a 'etailed description of the a:cident seg2once which w>uld succesafuny challenge the coolanc icurdary at 661 MJs or leas.

b. Idmt! fy all arnlysen, to:,ts, or any other data which I

stpport Intervenzs' respense to this interrogatzy.

c. Identify all documents titich stpport Intarverors' resinne to this interrogatTy.

Response

Intervenors can neither agree nor disagree with this

. s ta tem ent , since they have not completed their analysis of the SER.

Inte rrogatory

53. Identify ard describe all sodita/ concrete interacticns as roted in cantantion 3.c) which Intervenzs believe have rot been adegsately aralyzed,

a. Describe in detail the basis for the contention.

b. Identify an doctments which stpport Intervences' response to this interrogatory.

Response

See Appendix A of the SER.

In te rroga tory

54. State whether Intervenors believe that a loss-of-flow (IDF) accidet will result in an energetic evet.

a. If so, Irovide the precise sequence of events which win occur duriry the initiation of such an accident,

b. If so, describe the precise seq 2ence of events which win occur charing the moltout phase of the accident.

c. If so, describe the precise sequerre of events sich

will occur during the pool phase of the accident.

d. Describe all analyses, tests, or any other &ta which stpport Intervenors' response to this interrogatory.

e. Identify all doctanets whidt support Intervences' response to this interrogatory.

Response

This event is a function of probability. Inte rvenoru have not conducted an independent analysis of the IEF accident, but rely on analyses conducted by the Staf f and Applicants and their cons ul tants . Intervenors have rot completed their analysis of the SER in this regard .

In te rroga tory

55. State whether Intervenors believe that a transient over pour (TOP) accident will result in an surgetic event.

a. If so, describe the precise sequence of events of such an accidett & ring the initiation phase.

b. If so, describe the precise seq 1ence of events which will occur during the meltout phase of such an accident.

c. If so, describe the precise sequence of events which will eco.tr &tring the pool phase of such an accidett.

'd. Identify all amlyses, tests, or any other data which stpport Intervencrs' resprise to this interrogatcry

e. Idettify all documents dtich apport Interveurs'

( response to this interrogatcry.

Response

Inte rvenor s' answer regarding TOP accidents is the same as their answer regarding LOF accidents in Interroga tory 54 above.

Inte rrogato ry

56. Other than an IM or TCP accident, are Intervenors amre of any other accident seq 1erce whidi could I ntentially result in an energetic event?

i f

l l .. _

a. If so, describe the precise sequence of events which will occur during the initiation phase of such an accident. .

b. If so, describe the precise sequence of events & ring the moltout phase of such an accidet.

c. If so, deseibe the precise sequence of events & ring the pocL phase of such an accident.

d. . Identify all aralyses, tests, or any other data whi&

suppxt Intervencrs' response to this interrogatory.

e. Identify all documents which stpport Intervenors' respcmse to this interrogatory. ,

Response

Recriticality events, if they are r;ot treated as part of the LOF or TOP sequences. See Answer 54.

Inte rrogator y f

57. Identify aay structuni &ta ard/w aralyses contained in CIBRP 3 Vol.1, with Wich Intervences disagree.

a. As to any such data or amlysis identified above, j describe in detail the basis for Intervenors' disagreement.

b. Identify any aralyses, tests, or any other data which support Intervencrs' position.

c. ' Identify all docunents which stpport Intervenors' response to this interrogatcry. '

Response

Intervenors are not aware of any at this time other than the Staff analysis in the SER.

1

Inte rrogatory

50. State whether Intervenors agree that, assuning no failure of contairunent & ring the initiatirg phase of an ICDN ccntairunent integrity without venting would be maintained for note than a &y 4

followirg penetration of the reactor vessel ard guard vessel.

a. If Intervenors disagree, deseibe in detail the basis fee this disagreenent. The answer to this interrogatey must include a detailed descripticm of the sequerce of events which would lead to a failure of contairunent integrity af ter the initiating phase of the a:cident.

b. Identify ard describe in detail all aralyses, tests, or any other &ta which support Intervencrs' position.

.- - - _ .,~.. - - , _ . - .- . _ - . _ _ , . . - . _ . - - - _ . _ .

i

c. Identify all doctments which stppart Intervenors' response to this interrogatcry.

Response

Intervenors do not believe the data provided in the SER s upports a conclusion thatdne can rely on containment integrity for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

In terroga tory

59. State mether Intsrvenors agree that, asstning rn failure of containnet during the initiating phase of an IEDA, containamt capability above the Mse mat would be maintained irdefinitely by controlled veting and purging,

a. If Intervenors disagree, describe in detail the basis for the disagreenet. The respmse to this Interrogatcry alust incitee a detailal descripticn of the seq 2ence of events Wich w)uld lead to the failure of ccntainment integrity.

b. Identify all doctanents which stpport Intervenors' ,

response to this interrogatcry.

Response

Whether containment integrity would be maintained through venting will depend on several important f ac tor s , i ncluding operator training, the quality of instrumentation, construction quality control, and the confidence one places in the prediction of the containment capability and the physical phenomena inside the reactor cavity and containment f ollowing meltthrough.

Inte rrogatory

60. State whether Intervenors disagree with any of the equipnet quali fication requirenets describel in CRBRP III, Voltane 2.

a. If so, descriN in detail the Msis for Intervenors' disagreenet,

b. Describe any alternative requirements which Interverors believe should be adopted ard the basis for the alternative.

~. _ - -. -

c. Idetify all doctamts which stpport Interverurs' respcnse to this interrogatmy.

j Response Inte rvenors have not performed such an analysis . See Answer i

j. 39. Intervenors believe if a CDA were treated as a containment DBA, more stringent requirements would be impo sed , including, for example, adoption of the single-f ailure criterion for containment safety systems.

In te rroga tory

- 61. State tether Intervenors believe that any of the features of the Applicants' thermal margin beyoni design base clean-tp systect am inadecpate.

a. If so, identify the precise feattres dtich Interwwers i believe are inadegaata ani describe in detail the basis fx Intervenors' position,

b. Idetify an5 describe any alternative features which Intervenxs believe should be irr:aporatet in Clindt River in order to acMate thermal margins beyorri the desicpt base accidets ard state the basis for such alterratives.

c. Idetify all doctments which stpport Intervenors' response to this interrogatory.

Respo nse Yes. See Answe r 39 above.

I~

In te rroga tory

62. Describe in detail any criticisns whids Intervenors have of Applcicants' analysis of ICIA energetics.

l a. As to any criticism idetified above, idetify ani I describe any analyses, tests, prix experience, T any other data Widt stpport Intervenors' criticism,

b. Idetify all doctamts whidt stppwt Intervenzs' response to this interrogatory.

! Response l See Answe r 39.

l

Inte rrogatory

63. Describe in detail any criticism which Intervenors have of Applicants' analysis of seditan corcrete reaction ecntainel in CERP III, Vbl. 2.

a. As to any such criticism, identify ani describe any analyses, tests, prict experience, cr any other chta which stppcrt Intervenors' criticism.

b. Identify all da:tanents which stpport Intervenors' response to this interrogatcry.

Response

See Answe r 39 and the SER.

In terroga tory

64. Describe in detail any criticisms which Intervenors have of Applicants' analysis of the radiological ccnsequerces resulting from an HCIA at GBRP containsi in CRBRP 3, Vol. 2.

a. As to any such criticism, identify ard describe in detail any amlyses, tests, Ericr experience, or any other data which stpport Intervencrs' criticism,

b. Identify all docunents which stpport Intervenors' response to this interrogatcry.

Respo nse These we re set forth in our LWA-1 testimony.

In terroga tory

65. Describe any criticisus dtich Intervalors have of Applicants' aerosol behavior calculaticns ccntained in CRBRP 3 Vol.

2.

a. As to any such citicism, idetify ard describe in detail any analyses, tests, price experience, cr any other chta whidt stpport Intervenors' criticism,

b. Identify all doctments which support Intervencrs' response to this interrogatory.

Response

See Answe rs 39 and 64.

In te rroga tory

66. Describe the term "envirormental corditions" as ussi in

1 j

1 Intervenors Ccntenticn 10.

a. Describe the precise environmental conditicns Wich Intervenors believe will prevent the CRBRP frca maintaining safe cold stut-dom ard contairment integrity.

Response ,

Intervenors hereby withdraw Contention 10. Any remaining concerns we have in this regard are adequately covered by Contentions 1, 2 and 3.

In te rrogatory

67. Identify any exEerts Intervenors interd to call as witnesses in swpcrt of Contenticms 1, 2, 3.

a. As to eech such expert, Erovide the following infcrmation: (1) educational bacxground; (2) employment backgrourd;

(3) a listing of all hearincy in Which the expert has tescified as a witness concerning accident analysis of ruclear power plants; (4) a listing of all articles, books, studies or other dccments Irepared by the expert on accident analysis at nuclear poter pl. ants.

2 Response Undecided .

Inte rroga tory

68. With regard to Dr. Thomas Cachoran, provide the infcreation requestel in Interrogatcry 66.

Response

This question makes no sense, even assuming the correct spelling of "Cochran" .

Inte rrogatory

69. Identify all accuments Wich Intervenors interd to 4

introchee into eviderce at the ccnstruction permit hearings.

Response

Inte rvenors have not decided .

-1 1-,,w v + e,-------ere.+m---n.----w-v - , - - --,--,--,4wwwve n e --- =v----n-,-.-..m- -

--s------ -t - - -- - ----*---- - - - -- -

Respectf ully submitted, I

kit U

Ba rba ra A. Finamore S. Jacob Scherr Natural Resources Def ense Council, I nc .

1725 I Street, hW, #600 Washington, D.C. 20006 (202) 223-8210 Attorneys for Natural Resources Defense Council, Inc., and the Sierra Club Dated: April 22, 1983 i

- .