ML20073S881

Response to Applicant 830421 Tenth Set of Interrogatories. Related Correspondence

ML20073S881
Person / Time
Site:	Clinch River
Issue date:	05/06/1983
From:	Finamore B National Resources Defense Council
To:
References
NUDOCS 8305100210
Download: ML20073S881 (10)

Text

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UNITED STATES OF AMERICA p g.

NUCLEAR REGULATORY COMMISSION '- MAYO 61983>

ATOMIC SAFETY AND LICENSING BO gg b ketimz &Sar.

Before Administrative Judges: 8 Marshall E. Miller, Chairman 6 a Gustave A. Linenberger, Jr. 2 Dr. Cadet H. Hand, Jr.

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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

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(Clinch River Breeder Reactor Plant) )

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RESPONSE OF INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TO APPLICANTS' TENTH SET OF INTERROGATORIES DATED APRIL ~21,~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 Defensc Council, Inc. and the Sierra Club, hereby respond to Applicants' Tenth Set of Interrogatories, dated April 21, 1983.

0305100210 830506 ,

PDR ADOCK 05000537 PDR g

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.

INTERROGATORIES Interrogatory

1. Describe in Satail the basis for Intervenors' belief that a protective acticn guide for bone exposure is necessary for CRBRP.

a. Identify all h=arits which support Intervenors' response to this interrogatory.

Response

1. The basis for Intervenors' belief is that bone surface dose may be controlling in terms of radiation absorbed dose commitment.

a. SSR, SER, Intervenors', Staff's and Applicants' testimony in the LWA-1 proceeding.

Interrogatory

2. Describe in detail the basis for Intervenors' belief that there is a "potentially high dosage associated with grourdshine from fallout" of strong ganna emitters during cloud passage. See Intervenors' response to interrogatory 21, Applicants' EiM Set of Interrogatories,

a. Quantify the phrase "high dosage" as used in Intervenors' response to interrogatory 21.

b. List all strong ganea emitters which Intervenors believe will cause hi@ groundshine h fran fallout during cloud passage.

c. Identify and describe in. detail all analyses, studies, experimental data, or any other data, A ich support Intervenors' belief that fallout of strong gaimna emitters during cloud passage will result in hi@ groundshine h.

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

Response

2. The basis for Intervenors' belief is Dr. Morgan testimony in the LWA-1 proceeding that from his experience he believed the groundshine dose from Na-24 may exceed the dose due to inhalation or immersion. That the dose due to groundshine can exceed the dose due to inhalation and immersion is also suggested by WASH-1400, Figure VI 13-1, p. 13-2. It is clear from the isotopes listed that strong beta, as well as gamma, contributions are important.

a. In this context Intervenors mean controlling and exceeding guidelines values. We have not quantified it,

b. Na-24 plus the fission products identified in WASH-1400, Figure VI 13-1 are candidates. As noted above, beta emitters must also be considered. Intervenors have no list.

c.-d. See WASH-1400 and Effects of Nuclear Weapons by Gladstone and Nolan.

Interrogatory

3. Describe in detail the methodology which Intervenors believe should be used in establishin3 the plume exposure EPZ.

a. Identify all documents which support Intervenors' methodology.

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Response

3. Intervenors have not yet identified such methodology.

Interrogatory i

4. Identify the distance to the boundary of the plume exposure pathway EPZ which Intervenors believe should be established for CRIRP.

a. Describe in detail the basis for Intervenors' plume exposure pathway EPZ.

b. Identify all analyses or studies performed by Intervenors dtich support their plume exposure pathway EPZ.

c. Identify all documents which support Intervenors' j

response to this interrogatory.

Response

4. The distance is not fixed but should be a function of the projected radiation doses. Intervenors do not believe Applicants and Staff have made a case that a 10-mile plume exposure EPZ boundary is adequate.

a

a. Intervenors have not established the boundary.

b. None.

c. Intervenors have not conducted a literature survey for this purpose. Intervenors are aware of studies such as WASH-1400 that indicate high exposures are calculated for distances beyond 10 miles, depending on the release assumptions and assured meteorological conditions.

Interrogatory

5. Describe in detail the basis for Intervenors' belief that ground contamination levels should be taken into account in establishing the boundary of the plume exposure pathway EPZ.

a. Describe the methodology which Intervenors believe should be used in determining ground contamination levels.

b. Describe any analyses or studies which Intervenors have performed of the greurvi contamination levels following an accident at (3URP.

c. Identify all h e ts which support Intervenors' response to this interrogatory.

Response

5. All potential exposure pathways should be considered, and ground. shine and resuspension are two potential exposure pathways. Given that key personnel at nearby facilities, e.g.

Y-12, are required to remain on site, plans should be made to control personnel and vehicle contamination and otherwise limit exposure.

a. Intervenors to date have not attempted to identify the appropriate methodology,

b. None.

c. WASH-1400.

Interrogatory

6. Describe in detail the basis for Intervenors' belief that there is a " potential for high doses following a CIA prior to completion of evacuation." Intervenors' response to interrogatory 27, Applicants' Eighth Set of Interrogatories.

a. Quantify the phrase "high doses" as used in Intervenors' respcmse to interrogatory 27.

b. Identify and describe in detail all analyses, studies or experimental data which support Intervenors' belief that there is "a potential for high doses following a CDA prior to ccmipletion of evacuation."

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

Response

6. The analysis in Appendix A of the SER supports the conclusion that there is a potential for early venting. The SER

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l also provides dose calculations that are indicative of high doses following venting.

a. Intervenors have not quantified this phrase, but doses in the range of the 10 CFR 100 guideline values would qualify.

b. Intervenors' LWA-1 Testimony.

c. Intervenors' LWA-1 Testimony.

Interrogatory

7. Describe in detail what Intervenors believe to be the purpose of the plume exposure pathway EPZ.

a. Identify all documents drich support I'ntervenors' response to this interrogatory.

Response

7. The purpose is to protect public health by insuring adequate planning for nuclear emergencies, particularly those involving core melt where there is a potential for doses exceeding PAGs.

a. NUREG-0654, SER.

Interrogatory

8. Describe in detail the basis for the statement in Intervenors' response to Applicants' interrogatory 31, Applicants' Eighth Set of Interrogatories to Intervenors, that "the time period available for evacuation is too short under some scenarios." The answer to this interrogatory must include a detailed description of all scenarios in which the evacuation time period is "too short."

a. For each scenario identified above, quantify the phrase "too short" with respect to that scenario.

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

Response

8. The basis for the statement is the analyses of the potential for early venting in the SER Appendix A. The scenarios are those discussed in Appendix A where venting occurs on the order of 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> or less. They generally involve making conservative assumptions in the analyses. A longer time period

( ~7 9 hr.) may be appropriate if the plume exposure EPZ is found to exceed 10 miles.

a. Less than the evacuation time.

b. SER.

Interrogatory

9. Describe in detail all analyses or studies performed by Intervenors Whi& demonstrate that there is a "potentially short evacuation time in the event of an accident at CRBRP."

a. Identify all h e ts dti d support Intervenors' respcnse to this interrogatory.

Response

9. See SER and response to Interrogatory 8 above.

Interrogatory

10. Identify and describe in detail all studies or analyses performed by Intervenors Which demonstrate that there would be a significant release of plutonium in the event of a CDA at CRERP.

Response

10. We have nothing to add at this time to our LWA-1 testimony regarding the potential releases following CDAs.

Interrogatory

11. Describe in detail the basis for Intervanors' belief that off-site decontamination facilities would be necessary in the event of an accident at GBRP.

a. Describe in detail the precise accident sequences which Intervenors believe would require off-site decontamination facilities.

b. Identify all documents which support Intervenors' responnse to this intenogatory.

Response

11. Facilities may be needed to decontaminate personnel who continues to work at ORGDP and Y-12, after they traverse the EPZ upon leaving the plant.

a. CDA.

b. SER, Intervenors' LWA-1 testimony.

Interrogatory

12. Describe in detail the basis for Inter'renors' cont ( ; ion that reentry and rehabitation PY,'s should be established fo.

purposes of emergency planning.

a. Identify any regulatory requirements of which Intervenors are aware which require an emergency plan to er-

nass reentry and rehabitation.

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

Response

12. PAG's are needed to minimize potential exposure of key personnel that must continue to work at nearby facilities such as Y-12.

a. None are known,

b. FEMA-REP-1.

ADMISSIONS Admission

1. Intervenors have performed no analyses or studies establishing that there is a potential for high <haaa following a C[a prior to empletion of evacuation.

Re'sponse

1. Deny. Intervenors have provided LWA-1 testimony and read the SER.

Admission

2. 'Ihe major inpediments as set forth in Intervenors' contention 9(c) are "the potential for high th=aa following a ca prior to empletion of evacuatien."

Response

2. Can neither admit nor deny since our analysis of the SER is incomplete.

Admission

3. Intervenors have done no analysis of evacuation times for an EPZ greater than ten miles.

Response

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3. Admit.

Admission

4. '1he basis for Intervenors' contention 9(c) that the PSAR contains insufficient analysis cf the time requirement to evacuate various sectors and distances within the plume exposure pathway EPZ for transient and permanent population, is that the PSAR analysis of evacuation times is limited to a ten mile EPZ.

1 1

Response

4. Admit.

Respectfully submitted, L Mf**r.W f.-

Barbara A. Finamore S. Jacob Scherr Natural Resources Defense Council, Inc.

1725 I Street, NW, #600 Washington, D.C. 20006 (202) 223-8210 Attorneys for Natural Resources Defense Council, Inc., and the Sierra Club Dated: May 6, 1983 l

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