ML20079P697

Supplementary Response to Eighth & Ninth Set of Interrogatories & 08.Review of SER & Related Documentation Incomplete,Hindering Response to Certain Interrogatories.Related Correspondence

ML20079P697
Person / Time
Site:	Clinch River
Issue date:	05/06/1983
From:	Finamore B National Resources Defense Council, Sierra Club
To:	Hand C, Linenberger G, Mark Miller Atomic Safety and Licensing Board Panel
References
NUDOCS 8305100350
Download: ML20079P697 (15)

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UNITED STATES OF AMRICA '

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges

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

Dr . Cade t H. Hand, Jr .

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In the Matter of )

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UNITED STATES DEPARTMENT OF ENERGY )

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

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(Clinch River Breeder Reactor Plant) )

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INTERVENORS ' SUPPLEMENTARY RESPONSE TO APPLICANTS ' EIGHTH AND NINTH SET OF INTERROGATORIES DATED AP RIL 1, 1983 AND AP RIL 8, ' 1983 Pursuant to 10 G R { 2.740, Intervenors, Natural Resources Def ense Council, Inc. and the Sierra Club, hereby supplement their responses to Applicants' Eighth and Ninth Set of Interrogatories (dated April 1,1983 and April 8,1983), which _

were previously filed by Intervanors on April 14, 1983 and April 22, 1983.

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EIGCTH SET OF INTERROGATORIES Interrogatory

33. With respect to Thcmas Cochran, trovide the infccmaticn requested in Interrogatcry 32.

[ Interrogatory

32. Identify any experts who Intervenors interd to call as witnesses in support of Ccntention 9.

a. As to each such expert, Irovide the following infcreation:

(1) educaticnal tackgrotmd; (2) employment background; (3) a listing of all energency plans fcr nuclear power plants reviewed by su& expert; (4) a listing of all hee. rings in whi& the expert has testified as a witness cn energency planning at nuclear power plants; (5) a listing of all articles, books, studies cr other doctments Irepared by the expert en emergency planning; (6) a listing of all emergency plans for nuclear plants Irepared by the expert in diole cr in Imrt.]

Response (to Interrogatory 33)

Thomas Cochran 32(a)(1) This inf ormation was provided to Applicants in the course of the CRBR LM-1 proceedings.

(2) This inf ormation was provided to Applicants in the course of the CRBR LR-1 proceedings.

( 3) None. ,

( 4) None.

( 5) Cane.

( 6) None.

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NINTH SET OF INTERROETORIES

] Interrogatory

15. Identify ard describe all initiators, seg2ences, ard/or

! events not enveloped by Appliants' desip basis accidents that Intervonors believe are: 1) eedible ard 2) could lead to reduced heat reoval from the core cr ex:ess heat generaticn in the core.

a. Decibe in detail the insis for any additicral.

initiators, sequences, an4/w events Which Intervances believe are

credible ard diich could lead to reduce 5 heat removal frca the core

! cc escess heat generation in the core.

b. As to each initiator, seg2ence, or event described above, state the basis for Intervenes' belief that such initiatcc, segaence er event is medible.

! c. Identify ard describe all analyses, tests, prior i experience er any other data which support Intervances' position that six:h additicnal initiator, seg2ence, or event is credible.

d. Identify all doctments which support Intervances' response to this interrogatory.

Response

a.-d. Cms. The basis for Intervenors' belief s we re l

provided in Intervenors' IM-1 testinny. Initiators of Cms are described in numerous documents by Applicants, Staff and other authors , e .g. CRBRP-1, and Waltar and Reynolds , Fast Breeder Reactors.

Interrogatory

16. Stata diether Intervances agree that the following four (4) categories of desip features are n-ry ard sufficient to prevent initiation of an hypothetical care disrtptive accident (HCM): (1) the reactor shutdown systems; (2) the shi*% heat removal systems; (3) means to prevent 3rimary heat transport system (PHYS) pipe leahn larger than the desip basis leak; a11 (4) y feattres to prevent local idularce between heat generaticn ard heat reoval.

l a. If Intervanors disagree, deselbe in detail the basis

! for the disagreement, including a description of any additional or alternative design features diich Intervenors believe are necessary '-

to Irevent initiation of an HCm.

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b. As to each design feattre dessibed above, describe in detail the HCIA initiator whidt the yartictJLar feature is meant to Irevent.

c. Identify and describe any analyses, tests, grice experience or any other data which support Intervenors' res;onse to this interrogatory.

d. Identify all documents Whidt stpport Intervonors' rosynnse to this interrogatmy.

Res ponse Intervenors disagree with this statement. The detailed basis for this disagreement, as well as supporting analyses, tests, prior experience, data, and documents, are found in Intervenors' LNA-1 testimony and Proposed Findings of Fact. To date, Intervenors have not performed a detailed review to determine which additional or alternative design features are i

necessary, and believe such a review is the responsibility of Applicants and Staff.

Interrogatory

18. State whether Intervenors agree that either of the reactor shutdows systems is capable of shutting down the reactor and greventing McA initiation, assuming any single failtre within the operable systen (including the assumption that the most reactive control rod in the operable system does not insert.)

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

b. Identify all documents Which styport Intervonors' respcmse to this interrogatory.

Response

It is Intervenors' understanding that these systems are designed to meet the single failure criterion. At this time, Inteirvenors have not completed their analysis of the SER and related doctanents, and thus have insuf ficient information with which to agree or disagree with this statement. Intervenors do 1

, not believe that meeting the single failure criterion insures that Ctas are not credible, as Intervenors have defined the term i

" credible."

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Interrogatory  ;

19. state Wether Intervonors agree that the reactor shatdoet '

systems rely on proven technology.

a. If Intervenors disagree, describe in detail the basis for the disaf.r--_4., inciuding a descrigtion of the techncLogy which Intervenors believe is not already groven.

b. Identify all documents Which support Intervances' reasonse to this interrogatory.

Response

i Intervenors disagree with this statement. There has been insuf ficient experience with reactor shutdown systems, or with any of their technology, to " prove" that they will meet their j intended performance goals. To date, Intervenors have not i

conducted a review of the available literature to determine which i doctaments support our response to this interrogatory.

l Inte rrogatory

20. state Wether Intervenors agree that any one of the four  ;

overall shutdown Heat Renoval Systems paths has the cagability to  :-

independently reject the reactor decay heat. ,

a. If Intervances disagree, descriin in detail the basis for the disagreenent.

b. Identify all documents sich stpport Intervanors' response to this interrogatory.

Response

It is Intervenors' understanding that this interrogatory i paraphrases a CRBR design obj ective within the performance limits of Applicants' DBA envelope definition. . Intervenors have not

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! compl eted their analysis of the SER and related documents, and l

, thus have insuf ficient information with which to agree or i

disagree with this statement at this time.

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i Interrogatory 21 . state Whether Intervonors agree that angne of the heat transport systen paths in conjunction with the normal feedeter system or AFMi adegaately removes reactor decay heat without the use for operator acticn.

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

b. Identify all doctaients which stpport Interwnors'

respcmse to this interrogatory.

Response

Intervenors prestate that this interrogatory paraphrases a CRBR design obj ective. At this time, Intervenors have not completed their analysis of the SER and related documents, and j thus have insuf ficient information with which to agree or f

disagree with this statement.

Interrogatory

23. State 4 ether Intervonors agree that by placing thermal centers of the heat exchanging ocuponents at successively increasing i elevaticms in the plant, the three heat transsort system Iniths can remove shutdown decay heat using natural circulaticn.

a. If Intervonors disagree, describe in detail the tesis for the disagreement, including a detailed description of ths shysical prirciples sich would preclude nattral ciraalaticm.

Response

Intervenors agree that in order to remove shutdown decay heat using natural circulation, at a ministan, one must place thermal centers of the heat exchanging ccumponents at successively increasing elevations in the plant. Intervenors do not agree

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that such a factor alone will guarantee removal of decay heat by natural circulation. Other f actors , such as a s uf ficient pipe size, are also necessary bef ore natural circulation might occur. Intervenors believe that natural circulation cannot be reliably known until confirmed by tests. See transcript of LR-1 hearings on this issue, and the SSR for the basis of these views, and a description of the principles necessary f or natural circulation .

Interrogatory

24. State dwther Intervenors agree that by using the nattral I circulatica capbility, alcng with the ttriine driven auxiliary feed water ptmp, battery-gowered instrtaientatica ard control, the shutdom hast reoval systen capbLlity can be maintained even in the event of loss of all offsite power ani loss of all three cn-site diesel generators.

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

b. Identify all dcctanents which stpport Interwners' response to this interroptcry.

Responsa Intervenors disagree with this statement. The capacity of CRBR natural circulation to maintain the shutdown heat removal system cannot be reliably known until the CRBR is actually built and tested. Our LR-1 testimony and the SER describe the basis for the disagreement and support our response to this interrogatory.

Interrogatory

27. State whether Intervonors agree that the direct heat renoval systen is capble of renoving shutdom heat in the event the

! three heat transport system gaths are simultaneously ircapble cf l removing the shutdows heat.

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

b. Identify all doctaments dtich stpport Intervonors' l respcmse to this interrogatay.

{ Response i

j It is Intervenors' understanding that this interrogatory l paraphrases a CRBR design objective. At this time, Intervenors l l have not completed their analysis of the SER and related documents, and thus have insuf ficient information with which to agree or disagree with this statement.

j Interrogatory

. 29. State whether Intervenors agree that because the sodium

! coolant is maintained during operation at or near atmospheric

3ressure, thers is reducticm of the intamal force acting en the j PHTS ##ng, thus reducing the mechanism that could cause a small

. piping flaw to grow to boccuie a sack ard cause a small eack to I

develop into a major leak.

a. If Intervonors disacyee, deselbe in detail the basis

for the disagreenent. The respcmse to this interrogatory must include a detailei descripticn of the ways in which Intervenors believe a doublen-orded ppe rupture could cccw.

b. Identify all documents which styport Intervenors' respcmse to this interrogatay.

Response

At this time, Intervenors have not completed their analysis of the SER and related documents, and thus have insuf ficient

inf ormation with which to agree or disagree with this statement. Even if this statement were true, there is more than l one physical phenomenon (er " mechanism") involved in crack

, growth. See the Harris report cited by Intervenors in our LM-1 testimony.

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t Interrogatory

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4 34. Describe in detail any local html ance between heat generation and heat renoval which Intervenors believe could result in the iritiation of an HCIA at CIBM.

a. Identify all doctments wM& styport Intervenors'

response to this interrogatory.

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Response

. Intervenors have not completed our review of the SER, the I

PSAR, and related documents, and thus have insuf ficient inf ornation at this time with which to respond to this l j interrogatory. Our position to date on CDA initiation can be found in our LR-1 testimony and Proposed Findings of Fact.

j p terrogatory

35. Daseibe in detail the segaence of events other than an HCIA which Intervenors believe could &allenge the catairment at GE W.

! a. As to each seq 2ence of events, describe in detail the i centrolling paraneter (e.g., tenparature, pressure).

b. Identify all documents Whis stpport Intervenors' j response to this interrogatory.

Res ponse Loss of contairment could occur through human intervention,

{ e.g. operating the reactor not in accordance with proposed operat'ing procedures. To date, Intervenors have not perf ormed a review to determine particular sequences of events other than those associated with a CDA which could challenge the CRBR containment , or to determine the controlling parameter (e .g. ,

temperature, pressure) f or each such sequence of events.

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Intervenors believe it is the responsibility of Applicants and Staf f to perform such a review.

Interrogatory

37. state whether Intervonors agree that the control rods will react in aufficient time and with sufficient worth to achieve a talance between heat generation ani heat removal.

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

b. Identify all doctments Whi& stpport Intervenors' resp:mse to this interrogatay.

Response

It is Intervenors' understanding that this interrogatory l paraphrases a CRBR design obj ective. At this time, Intervenors 1

have not completed their analysis of the SER and related doctanents, and thus have insuf ficient inf ormation with which to agree or disagree with this statement.

Interrogatory

40. Dessibe in detail any iradeq2acies in Applicants' analysis of the ways in whid htman error can initiate, exacertate, or interf are with the mitigaticn of CRBW accidents,

a. Identify and describe in detail all human errors which can initiate accidents at CRBW arrl whid have not been adegaately analyzed by Applicants.

b. Identify and descibe in detail all hanan errors whi&

can exacerbate accidents at CIBW whl& have not been adegnately analyzed by Applicants.

c. Identify all haan errors Whi& can interfere with the mitigaticn of accidents at CIBM which Applicants have not adeq2ately analyzed. '

d. Identify all documents Whi& stpport Intervenors' response to this interrogatmy.

Posponse The inadequacies in Applicants' analysis of the ways in which htanan error can initiate, exacerbate, or interfere with the

e mitigation of CRBRP accidents are detailed in Intervenors' LR-1 testimony, particularly Part I and Part IV, pp. 22-25.

Intervenors have not perf ormed any review to date of the particular htanan errors which could initiate, exacerbate, or interf ere with the mitigation of CRBR accidents, and believe such a review is the responsibility of Applicants and staff.

Interrogatory

53. Identify ard describe all sodita/ concrete interacticns as noted in ccmtenticn 3.c) which Intervenors believe have not been adecpately aralyzed.

a. Describe in detail the insis for the contenticn.

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

Restense Intervenors believe that none of the sodium / concrete interactions described in SER Appendix A have been adequately analyzed by Applicants. The basis for this contention in that Applicant s' analysis of these interactions incorrectly classifies CDAs as outside the CRBR design basis, and thus utilizes insuf ficiently conservative assumptions. Intervenors' L M-1 testimony describes in detail the basis for the contention and supports our response to this interrogatory.

Interrogatory _

58. state whether Intervenors agree that, assuning no failtre of ccntainnent during the initiating phase of an HCDA, containnent intecyity without venting would be maintained for more than a day following penetraticn of the reactor vessel and guard vessel.

a. If Intervenors disagree, describe in detail the insis for this disagreenent. The answer to this interrogatory must include a detailed descripticn of the secperce of events which would

1 1 lead to a failure of containment integity af ter the initiating phase of the accident.

b. Identify ard desaibe in detail all aralyses, tests, or any other data which support Intervenzs' psiticn.

c. Identify all doctanents Witch stpport Interwners' respcmse to this interrogatory.

Response Intervenors disagree with this statement. The basis for our disagreement, and the analyses , tests, data, and documents supporting Intervenors' positicn are found in the SER. To date, Intervenors have not completed our analysis of the SER and

supporting documents, and thus cannot provide a detailed description of event sequences leading to containment f allure, l

other than that found in the SER.

I In terroga tory

61. State whether Intervenors believe that any of the features of the Applicants' thermal margin beyord desip base clean-tp system are inadegaate.

a. If so, identify the Irecise feattres which Intervenors believe are inadecpate arx1 describe in detail the basis for Intervenors' positicn.

b. Identify ard descibe any altamative feattres which Intervenors believe should be incorp3 rated in Clinch River in order to acemdate thermal margins beyond the desip tase accidents ard state the basis for such alternatives.

c. Identify all doctments sich stpport Intervences' response to this interrogatory.

Res ponse

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Intervenors maintain that inclusion of CDAs within the CRBR design basis, which requires use of conservative asstanptions, would reveal inadequacies in the present thermal margin beyond design base clean-up system. The present TMBIB features were designed based on the use of "best estimates" rather than

l conservative assumptions. To date, Intervenors have not performed a detailed analysis to determine which design f eatures  !

would be required if the CDA were treated as a DBA, and believe i

such an analysis is the responsibility of Applicants and staff.

Intervenors' L1R-1 testimony supports our response to this interroga tory .

Interrogatory

62. Describe in detail any criticians whicit Interwnors have of Applicants' analysis of HCIA energetica. ,

a. As to any criticisc identifisi above, identify ani i describe any analyses, tests, prior experience, or any other data i Which stpsort Intervenors' eiticism.

b. Identify all documents which support Intervences' res;onse to this interrogatory.

Response

our primary criticism of Applicants' analysis of CDA energetics is its use of "best estimates" rather than conservative asstanptions, resulting f rom a failure to treat CDAs ,

as containment design basis accidents. The detailed criticism of this approach, and any documents, analyses , test s, prior experiences, and other data of which we are aware supporting our l response to this interrogatory, can be f ound in Intervenors' LNA- l 1 testimony.

Interrogatory

63. Daseibe in detail any citicism which Intervonors have of I Applicants' analysis of sodita concrete reaction ocntained in CERP III, Vol. 2.

a. As to any such criticism, identify and densite any l analyses, tents, grior experience, w any other data which support j Intervenors' eiticism.

b. Identify all documents Wiich st.pport Interwnors' respmse to this interrogatmy.

Response

our primary criticism of Applicants' analysis of soditat concrete reaction contained in CRBRP III, Vol. 2 is with their use of "best est imate" rather than conservative assumptions, resulting f rom a f ailure to treat Cms as containment design bas is accidents. The detailed criticism of this approach, and any documents, analyses , tests, prior experiences, and other data of which we are aware supporting our response to this interrogatory can be f ound in Intervenors' LR-1 testimony and the SER.

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l Interrogatory

64. Describe in detail any criticissa Which Intervenors have of Applicants' analysis of the radiological consequences resulting from an HCIA at CRBW contained in CmW 3, vti. 2.

a. As to any such criticism, identify and describe in detail any aralyses, tests, Irior experience, or any other data whim support Intervenors' criticina.

b. Identify all doctments Whi& support Intervenors' response to this interrogatcry.

Response

Although Intervenors have not completed our review of the CRBRP-3 vol . 2 analysis of Cm radiological consequences , we have set forth all our current criticisms, and have ref erenced supporting analyses, data and doctanents in our LR-1 testimony.

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l Interrogatory ,

65. Describe any criticisse whi& Intervenors have of Applicants' aerosol behavior calculations contained in CERP 1 Vol.

2.

a. As to any sus citicism, identify and dessibe in detail any analyses, tests, prior expsrience, cr any other data whim stpport Intervenors' criticism.

b. Identify all doctments whi& support Intervances' l response to this interroptory.

Res ponse Inte rvenor s' main criticism of Applicants' aerosol behavior l

calculations contained in CRBRP-3 Vol. 2 is that they treat CDAs as beyond the containment design basis, and arer therefore based on best estimates rather than conservative assumptions. The detailed basis for this criticism, and all supporting analyses, j te sts , prior experience, documents, and other data, can be found in I ntervenors' LR -1 testimony. Intervenors have not completed their review of CRBPP-3 vol. 2, the SER, or related doctaments .

i Respectf ully submitted,

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Ba rbara A. Finamore S. Jacob Scherr Natural Resources Def ense Council, Inc.

1725 I Street, NW, #600 Washington, D .C. 20006 (202) 223-8210 Attorneys for Natural Resources Def ense Council, I nc. , and the l Sierra Club l

Dated: May 6,1983

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