ML20079F595
| ML20079F595 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 06/04/1982 |
| From: | Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club |
| To: | JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| Shared Package | |
| ML20079F592 | List: |
| References | |
| NUDOCS 8206080101 | |
| Download: ML20079F595 (25) | |
Text
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June 4 ["1982 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
)
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Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY
)
PROJECT MANAGEMENT CORPORATION
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TENNESSEE VALLEY AUTHORITY
)
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(Clinch River Breeder Reactor Plant)
)
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NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND THE SIERRA CLUB NINETEENTH SET OF INTERROGATORIES TO APPLICANTS Pursuant to 10 CFR S 2.740b, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, request that the attacned interrogatories be answered fully, in writing and under oath, by the indicated Department of Energy of ficial, or, in cases where no official is indicated, by one or more officers or employees of Applicants wno has personal knowledge or is the closest to having personal knowledge thereof.
If the interrogatories are 8206080101 820604 PDR ADOCK 05000537 O
. answered by more tnan one person, w'1 ether or not he or she verified the answers, and whether or not he or she is an officer or employee of any of the Applicants, such person's l
name and title should be set forth together with an identification of which interrogatories he or she is responsible for.
Unless otherwise indicated, each guestion is addressed to all Applicants.
In each question to all Applicants, each of the multiple Applicants is instructed to provide a separate answer.
Ho weve r, when all Applicants are in agreement on a response, only one uniform answer need be given.
Each answer to an interrogatory shall be preceded by a copy of the particular question to which the answer is responding.
Each question is instructed to be answered in six parts, as follows.
Answer to Question (a)
Provide the direct ansher to the question.
(b)
Identify all documents and studies, and the particular parts thereof, relied upon by Applicants, now or in the past, which serve as the basis for the answer.
In lieu thereof, at Applicants' option, a copy of such document and study may be attached to the answer.
(c)
Identify principal documents and studies, and the particular parts thereof, specifically examined but not cited in (b).
In lieu thereof, at Applicants'
. option, a copy of each such document and study may be attached to the ansker.
(d)
Identify by name, title and affiliation the primary Applicant employee (s) or consultant (s) who provided the answer to the question.
(e)
Explain whether Applicants are presently engaged in or intend to engage in any further, ongoing research program which may affect Applicants' answer.
This answer need be provided only in cases where Applicants intend to rely upon ongoing research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR.
Failure to provide such an answer means that Applicants do not intend to rely upon the existence of any such research at the LWA or construction permit hearing on the CRBR.
(f)
Identify the expert (s) if any, which Applicants intend to have testify on the subject matter questioned, and state the qualifications of each such expert.
This answer may be provided for each separate question or for a group of related questions.
This answer need not be provided until Applicants have in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasonable notice to Intervenors.
I l
. As used herein, " documents" include, but are not limited to, papers, photographs, criteria, standards of review, recordings, memoranda, books, records, writing s, letters, telegrams, mailgrams, correspondence, notes and minutes of meetings or of conversations or of phone calls, interoffice, intra-agency or interagency memoranda or written communications of any nature, recordings of conversations either in writing or upon any mechanical or electronic or electrical recording devices, notes, exhibits, appraisals, work papers, reports, studies, opinions, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, contracts, agreements, letter agreements, diaries, desk calendars, charts, schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (whether f ormal or informal) of any of the foregoing, and also all copies of any of the foregoing which dif fer in any way (including handwritten notations or other written or printed matter of any nature) from the original.
. INTERROGATORIES General Questions l
l 1.
Intervenors note that summaries of recent Staf f meetings with Applicants distributed to the service list contain relatively little information identifying positions of Staff and Applicants or concerning what was actually said at the meeting.
Have Applicants or consultants prepared any other writeups, summaries, or other documents related to such meetings other than those summaries circulated to the service lis t?
If the answer is yes, please identify and provide all such documents prepared since October 1, 1981.
Contention 1 2.
Applicants' updated response to Interrogatory III of Intervenors' Tenth Set of Interrogatories to Applicants refers to " preventive design features included in the CRBR" (lines 2-3 of response).
Have any of these preventive design features been included in LWRs and been shown to be effective in practice?
If the answer is yes, identify and describe each such preventive design feature, and explain in detail how its effectiveness has been proven.
1
. 3.
Review Applicants' updated response to each interrogatory in Intervenors' Tenth Set of Interrogatories to Applicants, filed April 30, 1982.
Would any of these responses change if the interrogatory requested only information necessary to the LWA-1 proceeding?
Describe each such change and explain the reason for each change.
4.
Identify all classes of accident initiators leading to CDAs for a reactor of the general size and type as the CRBR.
5.
Identify all relevant criteria to be applied to a reactor of the general size and type as the CRBR to ensure that CDAs are properly classified as within or outside the design basis.
6.
Identify in detail each general characteristic of the CRBRP design which Applicants believe should be considered at the LWA-1 stage.
7.
Identify and describe in detail each instance of control rod f ailure in the history of LWRs known to Applicants.
8.
Identify any calculations performed by Applicants of CDA analyses for the CRBR heterogeneous core that provide greater energetics or results that would suggest greater energetics than the results published in GEFR-00523.
___________J
. 9.
Identify and provide all reliability and probability analyses referred to in Applicants' response to Intervenors' Request for Admission #84 (related to Original Contention 2),
dated August 12, 1976.
10.
Describe in detail each additional " factor" leading to Applicants' position that CDAs should be excluded from the CRBR design basis referred to in Applicants' response to Intervenors' Reques t for Admission #86 (related to original Contention 2), dated August 12, 1976.
11.
Identify and provide all "probabilistic evaluations" used by Applicants to preclude CDAs from DBAs referred to in Applicants' response to Intervenors' Request for Admission #92 (related to original Contention 2), dated August 12, 1976.
12.
Identify each of the potential CDA initiators addressed in CRBRP-1 which was not previously identified in the PSAR.
Describe fully the methodology used by Applicants in selecting each such initiator and provide all documents in the possession of Applicants related to such methodology.
. Contention 2 13.
Regarding Interrogatory 2 (Contention 2) of Intervenors' Eighteenth Set of Interrogatories to Applicants:
identify each significant plant component (design feature) used to provide TMBDB whose design or other aspect has changed since April 23, 1977.
14.
Provide an updated ansher to Interrogatory II-l of Intervenors' Third Set of Interrogatories to Applicants, substituting for the indicated PSAR paragraphs the statements in Section 8.1.1.1 of CRBRP-GEFR-00523.
15.
Provide an updated answer to Interrogatory II-2 of Intervenors' Third Set of Interrogatories to Applicants, substituting for the indicated PSAR paragraph the statements in Section 8.1.1.2 of CRBRP-GEFR-00523.
16.
Provide an updated ansher to Interrogatory II-3 of Intervenors' Third Set of Interrogatories to Applicants, referring specifically to the heterogeneous core rather than the indicated PSAR paragraphs.
J
i
- 17.
Provide an updated answer to Interrogatory II-4 of In terv enor s' Third Set of Interrogatories to Applicants, substituting for the indicated PSAR paragraphs the statements in Section 8.1.1. 2 of CRBRP-GEFR-00523.
18.
Provide an updated answer to Interrogatory II-17 of Intervenors' Third Set of Interrogatories to Applicants, substituting for the indicated PSAR paragraph Section 8.2.4 of CRBR-GEFR-00523.
19.
With respect to the following requests for information, we are concerned with four distinct validations relative to the models and computer codes:
i) Validation that the code's output is the correct numerical calculation that should result from a given set of input data and the model assumptions; ii) Validation of the models against actual experimental data; iii) Validation that the models can be extended to the CRBR; and iv) Validation that the input assumptions for the CRBR case are adequate with respect to the CDA analysis, i.e.,
are supported by experimental evidence.
By " adequate" here and below, we mean that the calculations will not underestimate the CDA work potential (i.e.,
forces and resulting energetics of a CDA) or overestimate the containment capability of the reactor with respect to a CDA.
I
. I.
With respect to each of the following codes and each subroutine of each of the following codes:
(A)
SAS-3D (B)
SAS-4A (C)
EPIC (if not included in SAS-3D or SAS-4A, please provide the following information:
1)
Complete, current documentation (i.e., a writeup) of the codes and the subroutines.
2)
Identify, by name and affiliation, the author, or authors, of each model, subroutine, or portion of each subroutine, which each contributed or worked on.
3)
Identify by name and affiliation (including organization, division, branch, title, etc. ) each Applicant employee or consultant that has intimate working knowledge of the code and each subroutine, or parts thereof, including its validity.
Where more than one person is involved, delineate which portion of the code or subroutine with which each has an intimate working knowledge.
4)
Describe fully the procedures by which Applicants have assured themselves and continue to assure themselves, that the various computer programs (codes) accurately reproduce the models (see Validation 1) above).
5)
Indicate which models (including subroutines, or portions of subroutines) have not been validated as described in Validation i).
- 1 1-6)
Indicate the models (including subroutines, or portions of subroutines) or assumptions that have not been validated as described in Validation 1).
7)
For each model, portion of the model, or assumption that has been validated (against experimental (or o ther) data, see Validation 11) above), describe fully a) the procedure by which it was validated, b) the results, including all uncertainties and limitations of the validation, c) the source of the experimental or other data that was used in the validation.
l 8)
Explain fully a) all instabilities in the numerical performance in the models, b) what causes them, c) how they are avoided, and d) the extent to which this introduces uncertainties in the calculations and limits the validity of the model.
9)
To the extent that any answers to the above questions are based on referenced material not previously provided, please supply the references.
10)
Explain whether Applicants are presently engaged in or intend to engage in any further research or work which may af fect the answer.
Identify such research or work.
11)
Identify the expert (s), if any, whom Applicants intend to have testify on the subject matter questioned.
State qualifications of each such expert.
l
1
. II.
With respect to the Interrogatories identified above where final information was not provided, please provide the following information:
i) What is Applicants' present (preliminary) assessment in these areas?
- 11) What are the uncertainties that prevent Applicants from making a final assessment in these areas?
iii) What is the precise information that Applicants require to resolve these uncertainties?
iv) Are Applicants presently engaged in other research related to these areas?
Do Applicants intend to engage in such research in the future?
III.
Please identify each and every routine in 1) the entire SAS-3D code; 2) the entire SAS-4A code; 3) the entire EPIC code (if not included in the SAS-3D or SAS-4A codes).
Separately, for each routine identified above, please supply the following information:
(a) Was the routine verified by comparison with other codes, or by comparison with the results of hand calculations, or by comparison with what sound engineering judgment deemed to be physically reasonable?
(b) If the routine was verified by comparison with other codes, how was the other code or codes verified?
Identify the other code or codes.
. (c) If the answer to (a) or (b) above is that the routine was verified by hand calculations, please supply the hand calculations or the appropriate documentation, i.e.,
(i) the name(s) of the individual (s) who performed the calculations and made the comparison; and (ii) the laboratory notebook, merorandum or other written reord that documents the comparison.
(d) If the answer to (a) or (b) above is tnat the subroutine was verified by comparison with what sound engineering judgment deemed to be physically reasonable, please describe in detail the nature of and basis for the engineering judgment.
In addition, supply:
(i) the name(s) of the individual (s) who rendered the judgment and made the comparison; and (ii) the laboratory notebook, memorandum, or other written record that documents the comparison.
(e) Did the author (s) of the models actually perform the coding?
If not, identify the programmer (s).
4)
How do Applicants continue to assure themselves that the overall code and its subroutines accurately reproduces the models as described in the PSAR and its references?
5)
Please identif" and provide all intra-laboratory memoranda generated by personnel in the Accident Analysis Section, the Coolant Dynamics Section, and other Sections of the ANL Reactor Analysis and Safety Division that critique or
. otherwise evaluate the models developed by other personnel in these respective sections, limited to the development of any and all models and subroutines that are identified in 1) above.
Also provide all subsequent memoranda that are responses to criticisms or evaluations identified above or that represent a continuation of the dialogue related to the model evaluation.
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. C_ontention 3 i
20.
Describe fully the programs and methods used by Applicant to ensure that the analyses of potential accident initiators, sequences, and events are sufficiently comprehensive to assure that analyses of the DBAs will envelope the entire spectrum of credible accident initiators, sequences, and events.
21.
Was the program described in CRBRP-1 used by Applicants in any manner to ensure that the list of potential accident initiators, sequences, and events are sufficiently comprehensive to assure that analysis of the DBAs will envelop the entire spectrum of credible accident initiators, sequences, and events?
22.
Identify and produce all documents describing the programs or activities used by Applicants to ensure that the list of potential accident initiators, sequences, and events are sufficiently comprehensive to assure that analyses of the DBAs will envelop the entire spectrum of credible accident intiators, sequences, and events.
s
. Contentions 1, 2, and 3 23.
Regarding Interrogatory 8 of Intervenors' Eighteenth Set of Interrogatories to Applicants, specify what changes, if any, have been made in the design of the CRBRP since the TMI-2 accident as a result of lessons learned from that accident.
24.
Regarding Interrogatory 12 of Intervenors' Eighteenth Set of Interrogatories to Applicants:
explain the extent to which the statement of Mr. Clare, as described by Applicants, is also applicable to portions of the CRBRP design, other than the electrical portion.
25.
Ansher Interrogatory 16 of Intervenors' Eighteenth Set of Interrogatories to Applicants in reference to WARD-D-0118 and NEDM-14082, as originally requested.
26.
Regarding Interrogatory 17 of Intervenors' Eighteenth Set of Interrogatories to Applicants, do Applicants believe that the Board's Order Following Conference With Parties (April 22, 1982) permits Applicants to rely upon "probabilistic analyses of CRBRP accident risks and/or consequences" in any way during the LWA-1 proceeding?
If the answer is yes, describe in detail the extent to which such reliance is permitted.
r -
27.
Will Applicants rely upon "probabilistic analyses of/ CRBRP l
accident risks and/or consequences" in any way during the LWA-1 proceeding.?
If the answer is yes, describe each analysis, portion of analysis, or other factor, including the existence and general characteristics of such analysis, upon which Applicants intend to rely.
28.
In the NRC Workshop on Safety Goals (Ju ly 23, 19 81).,
R. M.'
Bernero noted the following specific problems with modelling and quantifying human errors:
1.
What individual pre-accident and post-accident I
human errors do we consider for quantification, and what is the basic data source?
2.
How do we account for important performance shaping f actors which modify the basic human error rates for the particular scenario being evaluated?
3.
How do we model and quantify dependent human errors which are coupled because of operator laxity, confusion, or misinterpretation ("mindset")?
r 4.
How do we model and quantify human actions which are "nonroutine" including' mitigation actions and
?
post-accident errors of commission?
Describe Applicants' precise methodology for dealing with each O
of the specific problems noted in 1-4 above.
Identify and r
produce any and all documents in the possession of Applicants related to such methodology.
\\
a t
s s
9 9
s
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/
- 7) I Contention 4 29.
What is the currently projected startup date for i
reprocessing of CRBR fuel (see ER Section 5.7-6)?
i 30.
'Is there a design basis threat for the SAF?
For the DRP?
For the SSTS?
If so, what is it?
31.
What does it mean to state that NDA verification will take ji -
place "as frequently as may be desired" (see ER Section
- 5. 7-4 2) ?
How of ten is this?
i
(
32.
Describe those ways in which the level of assurance in the
.SSTS, system is greater than in a commercial transport mode (see ER Section 5.7-46).
33.
How sensitive to loss will the DOE accounting system at v.-
the DRP be (see_ ER Section 5.7-56) ?
Put another way, wh at is the projected ID.for each inventory period (specify also the period) and on an annual basis.
34.
dilat specific actions have been taken to assure that DOE and NRC safeguards are " equally credible and comparably 5._
effective" (see Applicants Response to 16th Set of Interrogatories, p.
- 13) ?
._-____-_______________1______
. 35.
What specific f actors lead to the conclusion that co-location would not result in a significant impact on safeguards effectiveness (see Applicants' Updated Response to 12th Set of Interrogatories, p.
- 47) ?
36.
In light of Intervenors' Updated Responses, dated April 30, 1982, to discovery by NRC Staff (particularly.
Interrogatories 8 and 9), state whether you agree or disagree with the following statements:
a.
Small quantities of plutonium can be converted into a nuclear bomb or plutonium dispersion device which, if used, could cause widespread death and destruction, b.
Plutonium in an easily useable form will be available in substantial quantities at the CRBR and its supporting fuel cycle facilities.
If you disagree with all or part of either statement, state the basis for such disagreement.
37.
Is the current DOE safeguards system designed to protect SNM against diversion or thef t resulting from collusion between insider s?
If so, hoW?
How, if at all, does DOE's approach to the collusion threat differ from NRC's.
j
I
. Contention 6 38.
Identify in detail and produce each of the "other environmental impact documents" referred to by Applicants on 7':' R - -
line 3 of ER Amendment XIV (p. 3 (82-0034) [7, 1]
- 22).
39.
Answer Interrogatory 4 of Intervenors' Eighteenth Set of Interrogatories to Applicants by identifying each principal environmental impact associated with the operation of the Savannah River Plant (H Canyon and F Canyon) and the Idaho National Engineering Laboratory, and comparing it to the projected impact (if any) of the model reprocessing plant discussed in WASH-1535 and the Draft Supplement EIS (DOE /EIS-0085-D).
40.
Answer Interrogatory 5 of Intervenors' Eighteenth Set of Interrogatories to Applicants for the Savannah River Plant (H Canyon and F Canyon) and the Idaho National Engineering Laboratory.
41.
Explain in detail how the disposal of wastes from the CRBR spent fuel, including high level wates from processing, will be managed, since Applicants claim it is to be classified as commercial rather than defense waste.
. 42.
Identify all reasonably identifiable alternative sources of fuel for the CRBRP other than the Hanford PUREX plant.
43.
Provide the updated ansher to Interrogatory II.2 (a) of In tervenor s' Eighth Set of Interrogatories to Applicants for all core loadings.
If the ansher is not known, provide the relevant range of values and specify to the greatest degree possible how much fuel or how many loadings are likely to be obtained from the various grades of plutonium (e.g.,
f uel-gr ade or reactor-grade plutonium).
44.
For each possible source of fuel for the CRBR, other than those that are highly speculative, provide the following information as a function of time (e.g., by year) :
a.
the amount of plutonium that is likely to be utilized by the CRBR; b.
if the answer to (a) above is not known, the amount of plutonium that is available to be utilized by the CRBR; c.
the location of this source; d.
the probability that such source will be utilized, as compared to the other sources; e.
the current owner of the material.
45.
Identify the likely transportation routes (rail and truck) between the Hanford PUREX f acility and the CRBR.
l
. Contention 7 46.
Is it Applicants' position that the reliability goals of the Three Mile Island-2 reactor were met?
L 47.
Explain what is meant by " capital LMFBR" in Applicants' response to Interrogatory 1 of Intervenors' Eighteenth Set of Interrogatories to Applicants (section on Economic Feasibility).
48.
Have Applicants performed any analysis of the following alternative sites during the LMFBR demonstration plant site selection process:
a.
TVA Hartsville site?
b.
TVA Yellow Creek site?
c.
Washington Public Poker Supply System (WPPSS) Unit 4 site?
If the answer is yes, identify and provide all such analyses and all documents in the possession of Applicants relating to such analyses.
Describe the conclusions reached by Applicants and explain in detail the basis for all such conclusions.
If the answer is no, explain whether Applicants intend to perform such analyses, and, if not, why not.
. Contention 8 l
49.
Explain in detail what is meant by the term "30 effective full power years (EFPY)," how it dif fers, if at all, from the
" entire design lifetime of 30 years, in Applicants' answer to Interrogatory 1 of Intervenors' Ninth Set of Interrogatories to Applicants, and the reason for the change in terminology.
1
O 50.
Explain in detail the reason for each and every change in Tables 4, 5, and 6 of Applicants' ansher to Interrogatory 1 of Intervenors' Ninth Set of Interrogatories to Applicants, and identify and provide all references used by Applicants in making such changes, other than those listed in the response.
Contention 11 51.
Identify and provide all documents concerning " conflicting evidence" related to cancer induction in human beings resulting from irradiation at higher dose levels than those permissible under NRC regulations, referred to in Applicants' updated response tc Intervenors' Request for Admissian #9, dated July 28, 1976 (1-20).
Contention 14 52.
Have Applicants performed any analyses to determine whether CRBR systems will reach levels of neutron activation and contamination which require remote removal techniques?
If so, identify and produce all analyses, and describe the results of such analyses.
l
d
. Respectfully submitted, c/0h.~- /f c: n.,c c-Barbara A.
Finamore S. Jacob Scherr 1725 I Street, N.W.,
- 600 Washington, D.C.
20006 (202)223-8210 Ellyn Weiss Harmo Weiss 1725 I Street, N.W.
Washington, D.C.
20006 (202)833-9070 Attorneys for Intervenors Natural Resources Defense Council and Sierra Club l
l Dated:
June 4, 1982
.