ML20079F611

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Tenth Request for Admissions from Applicants.Related Correspondence
ML20079F611
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 8206080108
Download: ML20079F611 (10)
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Text

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ELATED COldlESPONDP37CH m
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J u ne:- 4 , 1982:

j UNITED STATES OF AMERICA ,

p NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Marshall E. Miller, Chairman Gustave A. Linenberger, Jr.

Dr. Cadet H. Hand, Jr.

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In the Matter of )

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) Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY )

PROJECT MANAGEMENT CORPORATION )

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 TENTH REQUEST TO APPLICANTS FOR ADMISSIONS ,

Pursuant to 10 CFR $ 2.742, and in accordance with the Board's Prehearing Conference Order of Feoruary 11, 1982, Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, request admission by Applicants of the truth of the following matters of fact.

l 8206080108 820604 DR ADOCK 050005{

4 ADMISSIONS Contention 1 l

1. The NRX reactor at Chalk River experienced a core disruptive accident (CDA) on or about December 12, 1952.
2. The No. 1 pile, an air-cooled graphite-moderated reactor at Windscale , UK, experienced a core disruptive accident on or about October 9, 1957.
3. The SL-1 reactor at NRTS (now INEL) experienced a CDA on or about January 3, 1961.
4. The HTRE-3 reactor at NRTS (now INEL) experienced a CDA on or about November 18, 1958.
5. The WTR reactor at Waltz Mill, PA, experienced a CDA on or about January 3, 1961.

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6. The FERMI-l reactor experienced a CDA on or about Octooer l

5, 1966.

7. EBR-1 reactor experienced a CDA, a core meltdown, on or about November 25, 1955.
8. The Three Mile Island Unit 2 reactor experienced a CDA on March 28, 1979.
9. The TMI-2 accident had significant safety implications.
10. If the information now available had been known wnen the Fermi reactor was constructed, design changes would have been made to take account of the currently known data.
11. If the information now available had been known when the TMI-2 reactor was constructed, design changes would have been made to take account of the currently known data.
12. With respect to a reactor of the general size and type as the CRBR, the determination of Applicants that a CDA need not be included in the spectrum of DBAs is a subjective determination.
13. With respect to a reactor of the general size and type as the CRBR, the determination of Applicants that a CDA need not be included in the spectrum of DBAs is an oDjective determination.
14. With respect to a reactor of the general size and type as l

the CRBR, the determination of Applicants that a CDA need not be included in the spectrum of DBAs is based upon qualitative judgments.

15. Applicants have not determined the probability of a CDA in a reactor of the general size and type as the CRBR in quantitative terms such as, for example, less than on chance in 4

10 reactor years.

16. Applicants have not quantitatively determined that the probability of a CDA in a reactor of the general size and type 4

as the CRBR is less than one chance in 10 reactor years with a confidence level greater than 90 percent.

17. Applicants have not quantitatively determined that the probability of a CDA in a reactor of the general size and type 6

as the CRBR is less than one chance in 10 reactor years with a confidence level greater than 90 percent.

18. While some probabilistic criteria have been employed, the ultimate decision that a CDA for a reactor of the general size and type as the CRBR does not h6ve to be considered as a DBA is based upon engineering judgment.
19. The decision that a CDA for a reactor of the general size and type as the CRBR does not have to be considered as a DBA was made in a deterministic manner as distinguished from a probabilistic manner.

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20. Since the decision that a CDA for a reactor of the general size and type as the CRBR does not have to be considered as a DBA was made in a deterministic manner, it is not possible to quantify the probability of the occurrence of a CDA.
21. Since the decision that a CDA for a reactor of the general size and type as the CRBR does not have to be considered as a DBA was made in a deterministic manner, the chance of

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occurrence of a CDA can onl;r be stated in subjective terms such as highly improbable or extremely unlikely.

22. Respond to Intervenors' Request for Admission 2, dated August 12, 1976, for the Enrico Fermi I plant and the Indian Point I reactor.

Contention 2

23. The discussion of the consequences of Class 8.5 accidents in che FES is based on assumptions used in the Parallel Design only, which has been withdrawn by Applicants.
24. The discussion of the consequences of Class 9 accidents in the FES is based on assumptions used in the Parallel Design 1

only, which has been withdrawn by Applicants.

Contention 4

25. In general, consideration of the internal threat to nuclear f acilities must be based on the following assumptions:
1) One person operating alone will probably remain undetected.
2) Instances of collusion involving 2-3 persons have been encountered in industry.
3) Most hijackings involve internal collution.
4) Key internal persons can be influenced by threats against their f amilies or other forms of blackmail.

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Contention 6

26. The transportation of SNM in the CRBRP fuel cycle will not comply with the provisions of 10 CFR Part 71.
27. The high-level waste from processing fuel at the Hanford PUREX plant would be classified as defense waste and managed in the same manner as other high-level defense waste at Hanf ord.
28. A comparison of the overall environmental impacts associated with the Hanford PUREX operation with the model reprocessing plant discussed in WASH-1535 and DOE /EIS-0085-D has not been made.
29. In the course of transporting SNM in the CRBRP f uel cycle, Applicants will not prenotify state authorities as required under 10 CFR Part 71.
30. In the transportation of SNM in the CRBRP f uel cycle, Applicants will not necessarily comply with routing requirements under Department of Transportation regulations in order to avoid populated areas.

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31. The Hanford PUREX plant does not currently meet the requirements of 40 CFR 190.

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32. Current DOE plans for the Hanford PUREX plant do not include incorporation of systems designed to capture and I

contain noble gases or other techniques necessary taa meet 40 CFR 190 requirements.

33. The Hanford PUREX plant is the most likely f acility for l supplying fuel for the CRBRP plant (see updated response to Interrogatory V-4 (Contention 6) of Intervenors' Eighteenth Set of Interrogatories to Applicants) .

Contention 11

34. Provide an updated response to Intervenors' Request for Admission 42, dated September 16, 1976 (21-42) ( April 30, 1982, updated response missing).
35. Respond to Intervenors' Request for Admission 9, dated July 28, 1976 (1-33), where " critical tissue mass" is defined as a mass of tissue of sufficient size to have the ability to trigger a carcinogenic response when subjected to ionizing r ad iat ion.
36. For purposes of protecting the health of workers and their progeny, it would be prudent to assume that irradiation of workers in the nuclear industry increases the risk of i

deleterious alteration in the germ cells of the workers and that those deleterious alterations may result in genetic defects in the progeny of those workers.

37. For purposes of protecting the health of workers and their progeny, it would be prudent to assume that irradiation of a female worker who is pregnant may result in the induction of

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cancer and in deleterious aberration in the germ cells of the j developing fetus. -' j

38. Please provide an updated answer to Intervenors' Request for Admission 42, dated September 16, 1976 (no updated answer provided on April 30, 1982). ,'

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Respectfully submitted, i

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Barbara A. Finamore S. Jacob Scherr 3

1725 I Street, N.W., #600

' Washington, D.C. 20006 (202)223-8210.

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Ellyn R. & iss Harmon & Weiss l 1725 I Street, N.W.

Washington, D.C. 20006 (202)883-9070

', Attorneys for Intervenors Natural Resources Defense Council and Sierra Club

'7 Dated: dune 4,; 1982 '

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