ML20079F577

Request for Admissions & Interrogatories.Certificate of Svc Encl

ML20079F577
Person / Time
Site:	Clinch River
Issue date:	06/04/1982
From:	Edgar G PROJECT MANAGEMENT CORP.
To:	National Resources Defense Council, Sierra Club
References
NUDOCS 8206080089
Download: ML20079F577 (15)

Text

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. UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION 1 :A 16

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

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TENNESEE VALLEY AUTHORITY )

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(Clinch River Breeder Reactor Plant) )

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APPLICANTS' REQUEST FOR ADMISSIGNS AND INTERROGATORIES TO NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND THE SIERRA CLUB Pursuant to 10 C.F.R. Section 2.742 and 2.740, the Department of Energy and Project Management Cororation for themselves and on behalf of the Tennessee Valley Authority request admission by Intervenors of the truth of the following matters of fact and answers to the following interrogatories.

t A. REQUEST FOR ADMISSIONS Please admit or deny the following matters of fact:

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1. The only portion of the PSAR which Intervenors believe constitutes a concession that the containment design is insufficient if conservative estimates are used in CDA analyses is the " existence of the Parallel design (since withdrawn) ." San Intervenors' Update to Applicants' First Set of Interrogatories at 8.

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2. Intervenors can identify no specific accident initiators, sequences or events which should be included within the spectrum of design basis accidents.

3. Intervenors cannot identify, and have no knowledge of the specific meteorological parameters for CRBRP, including wind speed, inversion conditions, frequency and other pertinant meteorological parameters, which Intervenors consider to be sufficiently unfavorable that an alternative site should be selected.

4. Intervenors cannot identify and have no knowledge of the specific value of each particular meteorological parameter for CRBRP, including wind speed, inversion conditions, frequency, and other pertinent meteorological parameters which Intervenors consider to be minimally acceptable for CRBRP.

5. There is an extensive base of LMFBR design, construction and operating experience which has been developed over the last 28 years, both in the U.S. and in other countries, which is available for use in the safety evaluation of CRBRP technology.

6. It can be safely concluded that HCDAs can be excluded aa design basis events considering this extensive LMFBR technological base in conjunction with the preventive design features included in the CRBRP.

7. ANL-RDP-23; ANL Monthly Progress Reports, December 1973; SAND 76-0273; NUREG-766501, July 1976; and the Applicants' computed results provide evidence that fuel axial expansion occurs even during power transients.

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- 8. There are relatively slow power changes occurring during the initial period of an LOF event.

9. During an LOF event, the early fuel axial expansion is a prompt negative feedback that can alter the energetics of the event as documented in Section 7.2.3 in CRBRP-GEFR-00523 and Section 7.2.2.3 in CRBRP-GEFR-00103.

10. Intervenors have no evidence that axial fuel expansion will not occur on the time scales required to alter the energetics of an LOF event.

11. In terms of the pressure pulse applied to the head under an HCDA load, the upper internals structure would attenuate the loads.

12. In light of Admission ll, neglecting the upper internal structure provides a conservative representation of the loads on the reactor closure head.

13. The shear ring is capable of retaining the reactor vessel head for the 661 megajoule HCDA case with a substantial margin to failure.

14. All changes in reactor vessel and core design relevant to accident modeling have been included in Applicants' accident modeling.

15. The only technical bases for Intervenors' contention that HCDAs are credible events are those listed in Intervenors' response to Interrogatory 3(f) of Applicants' Fourth Set of Interrogatories.

16. Intervenors have not performed any analysis which substantiates the claim that Applicants have not adequately considered in the radiological source term analysis the

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cnvironmental conditions in the reactor containment building created by the release of substantial quantities of sodium.

17. Intervenors cannet identify and have no knowledge of cny environmental conditions in the reactor containment building created by the release of substantial quantities of sodium which were not adequately considered i che radiological source term analysis.

18. Intervenors have no factual basis for the claim that Applicants have not adequately considered in the radiological source term analysis the environmental conditions in the reactor containment building created by the release of substantial quantities of sodium.

19. Intervenors agree with the leak rate assumptions appearing on III-19 of the SSR for the assumed core fraction released to the containment.

20. Intervenors have no technical basis for concluding that

" filters will [not] perf orm at the stated ef ficiencies in an environment where large quantities of sodium have been released and sodium and hydrogen combustion have taken place." Intervenors' Response to Interrogatory 3(j) of Applicants' Fourth Set of Interrogatories.

21. Intervenors have no technical basis for concluding that venting is an unacceptable method of accommodating HCDAs.

22. Intervenors' sole basis for concluding that Applicants have not adequately analyzed all accidents associated with core meltthroug,h following loss of core geometry and sodium-concrete interactons is that Applicants have not treated HCDAs as DBAs.

23. Intervenors cannot identify and have no knowledge of any population characteristics of the CRBR site which Intervenors

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. believe are sufficiently unfavorable that an alternative site should be selected.

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24. The only alternative sites which Intervenors believe have population densities which are more favorable than the population density of the CRBR are Hanford Reservation and Idaho National Engineering Laboratory. -

25. Intervenors have not analyzed and have no knowledge of the population densities of Hanford Reservation or Idaho National Engineering Laboratory.

26. The only "new knowledge" referred to in Contention 11 (Old 8) is contained in ICRP26, ICRP30, 40C.F.R. Section 190.10 and EPA 520/4-77-016.

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27. The only "recently discovered omissions" ref erred to in Contention 8 (Old 14) are the analyses of Nickel-59 and Niobium-94.

28. The only neutron activitation products referred to in Contention 8 (Old 14) are Nickel-59 and Niobium-94.

29. Intervenors have not analyzed and have no knowledge of the environmental conditions which they believe should be considered in the radiological source term analysics

30. Intervenors have no basis for the conclusion that any relevant or necessary environmental conditions were not considered in the radiological source term analysis. ,

31. Intervenors have not analyzed and have no knowledge of the maximum credible sodium release following a HCDA.

32. Intervenors' sole objection to Applicants' and Staf f's' accident analysis is that BCDAs are not included as DBAs.

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33. Intervenors agree with Applicants' analysis of accidents which are included within the design base.

34. Intervenors have not developed and cannot identify the specific acceptance criteria which Intervenors contend must be utilized to assure that core meltthrough accidents are adequately analyzed.

35. The only meteorological parameters or factors which must be utilized in evaluating site meteorology are wind speed and inversion conditions.

36. Intervenors cannot identify and have no knowledge of any sites with more favorable wind speed and inversion conditions than the CRBR site.

37. Intervenors have not analyzed and cannot identify any meteorological disadvantages of the CRBR site.

B. INTERROGATORIES

1. For each statement in the foregoing Request for Admissions which you deny, provide the following informations the specific portion of the statement which is not admitted and the documents (if any) and witnesses (if any) which provide the basis for your disagreement with the statement.

2. For each statement in the foregoing Request for Admissions which you can neither admit nor deny, provide the f ollowing information:

a. The portion of the statement which is not admitted, and the basis for your inability to either admit or deny the statement.

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b. If the basis is that you have not completed your analysis, please describe in detail the nature of the analysis being undertaken, the person (s) performing the analysis, the preliminary results of the analfsis, if any, and the date when you expect to complete your analysis.

3. If not provided in response to Interrogatory 2.c.

cbove, please provide the following information with regard to the

" analysis" referred to by NRDC in response to Interrogatory 3(c) of Applicants' Fourth set of Interrogatories to Intervenors: a detailed descr3ption of the nature of the analysis, any preliminary results of the analysis, the person (s) performing the analysis, the date when Intervenora expect the analysis to be completed, and if the analysis is complete, provide the results of the analysis including all assumptions made in performing the analysis, all data or information used in performing the analysis and identify all documents relating to or referring to such analysis.

l 4. In response to Interrogatory 3(g) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

l Intervenors believe such bounding releases would lead to very different assumptions regarding the environmental conditions in the reactor building, primarily due to the assumption that substantially more than 1000 lbs of sodium would be released.

With regard to this statement, please provide the following

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a. a detailed description of the "very different assumptions" referred to in the statement, and with regard to each such assumption, state the technical and/or factual basis for the assumption, and identify

all documents which Intervenors believe support each assumption, b '. Describe in detail the basis for the " assumption that substantially more than 1000 lbs. of sodium would be released", and identify all studies, analyses, reports

. or any documents which support the statement.

5. In response to Interrogatory 3(h) of Applicants' Fourth set of Interrogatories, Intervenors make the following statement:

The principal issue is the percentage of fission product and fuel (other than noble gases and halogens) that should be considered as part of the source term.

With regard to this statement, please provide the following informations

a. State the percentage of fission product and f uel (othet-than noble gases and halogens) that Intervenors believe ,

should be considered as part of the source term.

b. Describe in detail the technical and/or factual basis for the percentage including any analysis undertaken by Intervenors to arrive at this percentage and the person (s) who perf ormed such analysis,

c. Identify all studies, analyses or reports which support the percentage.

6. In response to Interrogatory 3(j) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

To date Intervenors have not performed any analyses that would lead them to challenge the leak rate assumptions appearing on p. III-19 of the SSR for the assumed core fraction released to containment.

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. With regard to this statement, please provide the following informations

a. State whether Intervenors intend to challenge the leak rate assumptions referred to in the statement and if so, provide the basis for the challenge to the leak rate assumptions including any analyses, reports, or studies supporting Intervenors' challenge.

7. In response to Interrogatory 3(j) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

We question whether Staf f/ Applicants have demonstrated that the filters will perform at the stated efficiencies in an environment where large quantities of sodium have been released and sodium and hydrogen combustion have taken place. Intervenors believe that venting is an unacceptable method of accommodating severe CDAs.

With regard to this statement, please provide the following information:

a. Describe in detail the technical and/or factual basis which lead Intervenors to question whether "the filters will perf orm at the stated ef ficiencies .. . " including a description of any analysis undertaken by Intervenors which leads you to question the ef ficiency of the filters and the identity of the person (s) who performed such an analysis.

b. Identify any studies, reports, or analyses which lead l

Intervenors to question the efficiency of the filters.

c. Describe in detail the technical and/or factual basis for Intervenors' belief "that venting is an unacceptable method of accommodating severe CDAs" including a description of any analysis undertaken by

l Intervenors which supports your belief that " venting is an unacceptable method of accommodating severe CDAs,"

and the identity of the person (s) performing such analysis,

d. Identify all analyses, studies, or reports which support Intervenors' belief that " venting is an unacceptable method of accommodating severe CDAs."

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e. Define the phrase " severe CDAs".

8. In response to Interrogatory 4(c) of Applicants' Fourth Set of Interrogatories, Intervenors state that "Our analysis is incomplete. ...

" With regard to this statement, please provide the following information.

a. Describe in detail the nature of the analysis you are conducting, including all assumptions made in performing the analysis, all data or information used, any preliminary results of the analysis, the person (s) performing the analysis, and the date when Intervenors expect the analysis to be completed.

b. If the analysis is complete, provide the results of the analysis and identify any documents which describe the analysis or the final results. ,

9. In light of Intervenors' response to Interrogatory 3-3.c. of NRC's let Round of Disc'overy in which Intervenors state that they have not yet developed scientific acceptance criteria to be used in judging the adequacy of core meltthrough accident analyses, explain the basis for Intervenors' Contention 3c which states that accidents associated with core meltthrough following

' ass of core geometry and sodium-concrete interactions have not been adequately analyzed.

10. In response to Interrogatory 6(a) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

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. s On the basis of additional analysis, Intervenors would modify the conclusion on p.13 of that document in the following respects.

With regard to this statement, please provide the following information ,

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a. Describe in detail the " additional analysis" referred to in the statement, including a description of any assumptions made, any data or information used, identify any documents relied upon and identify the person (s) who performed the analysis.

11. In response to Interrogatory 6(a) of Applicants' Fourth Set of Interrogatories, Intervenors make the following statement:

Regarding the ICRP Publication 26 approach, Intervenors currently believe the weighting factors and organ dose limits (" caps" to prevent non-stockastic effects) recommended by EPA should be used rather than those recommended by ICRP 26.

With regard to this statement, please provide the following information:

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l l a. Describe in detail all factors leading Intervenors to 1

believe that the EPA weighting f actors and organ dose limits should be used rather than those recommended by ICRP 26. The answer to this interrogatory should identify all reports, studies, or analyses which

. support Intervenors' belief.

b. Identify all documents relating to or ref erring to the weighting f actor or organ dose limits recommended by EPA and those recommended by ICRP 26.

Respectfully submitted, l

GeorgeG L. Edgar" Attorney for Project Management Corporation DATED: June 4, 1982 e

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

UNITED STATES DEFARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:

I *** Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

Dr. Cadet H. Hand, Jr.

Director Bodega Marine Laboratory University of California P.O. Box 247 Bodega Bay, California 94923

• • • Mr. Gustave A. Linenberger Atomic Saf ety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20545 i

• • • • Daniel Swanson, Esquire Stuart Treby, ' Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20545 (2 copies)

. *At; yic Saf ety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.C. 20545

• Atomic Saf ety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20545

• Dock,eting & Service Section Office of the Secretary  !

U. S. Nuclear Regulatory Commission l Washington, D.C. 20545 (3 copies)

The Honorable William M. Leech, Jr., Attorney General The Honorable William B. Hubbard, Chief Deputy Attorney General The Honorable Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 l

Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)

• • Dr. Thomas Cochran

Ms. Barbara A. Finamor e Natural Resources Defense Council 1725 Eye Street, N.W., Suite 600 Washington, D.C. 20006 (2 copies)

Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Ms.* Ellyn R. Weiss Harmon & Weiss l 1725 Eye Street, N.W., Suite 506 Washington, J.C. 20006

Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esquire Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830

• • Warren E. Bergholz, Esquire Leon Silverstrom, Esquire U. S. Department of Energy 1000 Independence Avenue, S.W.

Room 6B-256 Washington, D.C. 20585 (4 copies)

• • Eldon V. C. Greenberg, Esquire Tuttle & Taylor 1901 L Street, N.W., Suite 805 Washington, D.C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 George 1. Edgfr Attorney for Project Management Corporation

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

_ **/ Denotes hand delivery to indicated address. .

• • • / Denotes hand delivery to 4350 East-West Highway, Bethesda, Md.

• • • • / Denotes hand delivery to 7735 Old Georgetown Road (Maryland National Bank Building), Bethesda, Md.

June 4, 1982

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