ML20052E241

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Response to Fourth Set of Interrogatories.Prof Qualifications & Certificate of Svc Encl
ML20052E241
Person / Time
Site: Clinch River
Issue date: 05/06/1982
From: Finamore B
National Resources Defense Council, Sierra Club
To:
JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
References
NUDOCS 8205100227
Download: ML20052E241 (28)


Text

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r e g C0CKUD May 6,(1902( _g , 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

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Before Administrative Judges: . ;4

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Marshall E. Miller, Chairman g5 , ., : " .

h Gustave A. Linenberger, Jr. r-Dr. Cadet H. Hand, Jr.

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                                                         )                    bbl 1-In the Matter of                             )
                                                         )
                                                         )   Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY           )

PROJECT MANAGEMENT CORPORATION ) ' TENNESSEE VALLEY AUTHORITY )

                                                         )

(Clinch River Breeder Reactor Plant) )

                                                         )

RESPONSE OF INTERVENORS , NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB, TO APPLICANTS' FOURTH SET OF INTERROGATORIES Pursuant to 10 CFR S2.7400, and in accordance with the Board's Prehearing Conference Order (Schedule) of February 11, 1982, Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, hereby respond to Applicants' Fourth Set of' Interrogatories to Intervenors,-dated April 15, 1982.1/ 1/ ' Applicants and Intervenors met on April 23, 1982, at which time Applicants withdrew the questions indicated below. 3 s Q f

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2 The direct answer to each Interrogatory is provided below under eacn question. The requested additional information for each Interrogatory is as follows: (a) All documents and studies, and the particular parts thereof, relied upon by Intervenors, now or in the past, which serve as the basis for the answer are referenced in the direct answer unless otherwise noted. (D) There were no principal documents and studies specifically examined but not cited in (b) unless otherwise noted. (c) Dr. Thomas B. Cochran is the primary Intervenor employee who provided the answer to the question, un'less otherwise noted. (d) Dr. Thomas B. Cochran is the only expert witness Intervenors have identified to date. INTERROGATORY

l. For each admitted contention:

f (a) Please identify any documents, by author, title, publisher and date of publication which have come to the l l attention of Intervenors since this proceeding was suspended in. 1977 and whicn Intervenors intend to rely upon, in preparation for or at the hearing in this proceeding..

RESPONSE

1(a) No decision has been made as to which documents Intervenors will rely upon in preparation for the LWA-1 hearing-l _ V-l l

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3 other . than those which are part of the CRBR docket, Staff minutes of Staff / Applicants meetings, ACRS testimony, documents cited by Intervenors in "New Information Relevant to Intervenors' Contentions" (attached to the March 12, 1982, j letter to Staf f and Applicants' counsel from Intervenors) , and documents cited by Intervenors in response to Staff and Applicants' discovery requests. INTERROGATORY (b) Please identify the expert (s) , if any, who Intervenors intend to have testify on the subject matter of the contention and state the qualifications of each expert in terms of education and/or experience. (c) Please identify any ongoing research or analysis of which Intervenors are aware which relate to the subject matter of the contention. RES PONSE 1(b) , (c) These Interrogatories duplicate Interrogatory 1 of Applicants' First Set of Interrogatories to Intervenors. The responses are the same as given there. INTERROGATORY

2. For Contention 1 (Old 2)

(a) This interrogatory has been withdrawn by Applicants as  ; duplicative of Staff's discovery request to Intervenors.

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4 a (b) As to each "CDA initiator" identified in responsa to 2(a) above, including anticipated transients without scram, please provide a description of the minimum scope and detail of i i reliable data (including analyses, tests, data, compilations thereof, facts, opinions, or assumptions) which you consider to be necessary and sufficient to demonstrate that such "CDA initiator" has a sufficiently low probability that it may be excluded from the design bases for CRBR.

RESPONSE

2(b) CDA initiators other than anticipated transients without scram include events in the "unlikely" and " extremely-unlikely" categories in Table 15.1.3-2 of the PSAR. " There may be other such initiators. Indeed, we would expect this to be the case. A sophisticated and comprehensive fault-tree / event-I tree analysis would be required to reliably identify CDA 1 initiators. With regard to the minimum scope and detail required, Applicants appear to misunderstand the Contention: Neither Applicants nor Staf f have demonstrated through reliable data that the probability of anticipated transients without scram or other CDA initiators is suf ficiently low to enable CDAs to be excluded from the envelope of DBAs. Intervenors do not assert that each "CDA initiator" must be excluded from the design basis. (See also response to Interrogatory 2(a) of Applicants' First Set of Interrogatories to NRDC, et al.

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5 INTERROGATORY 2(c), (d), (e), (f) Withdrawn by Applicants, based on the Board's Order of April 22, 1982 deferring Contention 1(b) "for purposes of discovery and litigation until af ter the LWA-1 evidentiary hearing and partial initial decision." INTERROGATORY 2(g) Please describe specifically the " implications of the TMI-2 accident, particularly regarding the effects of human error in failure to scram" in relation to the CRBR.

RESPONSE

       .           2(g)        The response to this question is provided at pp. 3-4 of Natural Resources Defense Council's Response to Objections to Contentions, March 31, 1982.

INTERROGATORY

3. For Contention 2 (Old 3)

(a) , (b) Withdrawn by Applicants, as duplicative of Staf f's discovery request to Intervenors. I INTERROGATORY 3(c) Please identify and describe in detail each specific element of the analyses of CDAs .and their consequences by Applicants and Staff which you consider to be inadequate for [ demonstrating that the radiological source term for CRBRP would w g = , w, An m ,..%r=_ w M,g '*a, J

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4 i ? 6 result in potential hazards not excluded by those from any accident considered credible. The answer to this interrogatory must include a detailed description or explanation of the inadequacies in the analysis.

RESPONSE

3(c) Intervenors cannot fully answer this question because , we have not completed our analysis. Our current position on these matters has been set forth in updated responses to Interrogatories 2, 3, and 4 of Applicants' First Set of Interrogatories to NRDC, et al. , and Interrogatory 3 (f) below. 1

            . INTERROGATORY 3(d)     Please identify all changes in reactor vessel and core design which have not been included in Applicants' i                accident modeling, and which you believe snould have been so

. included. 1

RESPONSE

3(d) Intervenors are extremely talented but are not mind i' readers. Consequently, we simply don't know. Even if the question were more limited in scope, we would have to await and analyze updated responses of Applicants to identify what was included in Applicants' models. INTERROGATORY 3(e) Withdrawn by Applicants. 4

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k 7 INTERROGATORY 3(f) Please describe in detail the specific technical bases for Intervenors' contention that " radiological source term analysis snould be based on the assumption that CDAs (failure to scram with substantial core description [ sic]) are credible accidents within the DBA envelope, should place an upper bound on the explosive potential of a CDA, and should then derive a conservative estimate of the fission product release from such an accident. "

RESPONSE

i 3(f) 10 CFR 100.11 requires that a fission product release (source term) be hypothesized for purposes of site analysis; and that this release not be exceeded by the release from any accident considered credible. Intervenors believe CDAs are credible events. There are at least several fundamental reasons for this view: (1) CDAs or CDA initiators have occurred in Clementine, EBR-I and FERMI-I; (2) CDAs have been treated as design basis events in safety analyses of previous reactors, e.q, EBR-II, SEFOR, FFTF; (3) ' some members of the technical community believe CDAs are credible events and should be design basis events; and (4) neither Applicants nor Staff have demonstrated-otherwise for either CRBR or a reactor of this general size and type. Intervenors believe that, once a CDA has been initiated, it is prudent to assume that it will progress to whole core t

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4 % 8 involvement (see CRBRP-1) ; i.e., substantial core disruption. Intervenors' view that CDAs snould be included in the design l . basis envelope is based on prudence and circumspection. Intervenors' view tnat the upper-bound on the explosive i potential of CDAs should be used to establish the source ter'm follows from the language of 10 CFR 100 and the fact that the sequence of events as the accident progresses following substantial core disruption is so poorly understood that this is the prudent course to take. See US AEC, " Safety Evaluation of the Fast Flux Test Facility," Project 448, October 31, 1972; ANL, " Hazard Summary Report, EPR-II, ANL-5719, May 1957; T. J. Thompson and J. G. Beckerley,, The Technology of Nuclear Reactor Safety, 1964; Richard E. Webb, The Accident Hazards of Nuclear-Power Plants, 1976; John G. Fuller, We Almost Lost Detroit, 1975; ACRS, Transcript o f Meetings on March 3 0-31, 1982, and prior ACRS meetings on fast reactor safety issues. INTERROGATORY 3(g) Please identify and explain specifically why you believe the radiological source term analysis has inadequately considered (1) the release of fission products and core materials, and (2) the environmental conditions in the reactor ouilding created by release of suostantial quantities of l sodium. The discussion of deficiencies in the analysis must include any analytical standards wnich nave not been met. Ei- G b beJna. i L a u A u .La w =: .

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RESPONSE

3(g) Tne stated rationale for the " source term" currently used by the Staff and Applicants is presented in the May 6, 1976, Denise to Caffey letter, along with the basis for its selection (i.e. , CDAs can and must be excluded from the DBA ' envelope, use of a non-mechanistic analysis, extrapolation from LWR data) . Intervenors do not agree with the assertion that' CDAs can be excluded from the DBA envelope. A consequence of including CDAs in the DBA envelope is to. force the use of more J conservative assumptions regarding the CDA energetics, i . e., l larger " bounding" consequences (see ACRS Transcripts, March 30-31). 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.

INTERROGATORY 3(h) Please list any fission products and core materials 'i i other than halogens, iodine, and plutonium which must be j considered in the radiological source term analysis.

RESPONSE

1 3(h) All core materials and fission products must be considered. Applicants and Staff reach the same conclusion. The principal issue is the percentage of fission product 1

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l t ! INTERROGATORY 3(i) Please describe in detail the environmental conditions in the reactor containment building created by the release of suostantial quantities of sodium which you believe were not adequately considered in the radiological source term a na ly s is .

                   . RESPONSE 4                                 3(i)        Intervenors have not performed the analysis that we believe Applicants and Staf f should conduct to identify such environmental conditions.                   See response to Interrogatory 2-10.d . o f NRC Staf f First Round of Discovery to NRDC, et al.

INTERROGATORY

                              - 3(j)         Please describe in detail the inadequacies in the l

Applicants' or Staff's analysis of containment design. i

RESPONSE 3(j) To date Intervenors nave not performed any analysis 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. We question whether Staff / Applicants 1

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11 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. INTERROGATORY

4. For Contention 3 (Old 4)

! (a) Please identify and describe in detail all accidents

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1 associated with core meltthrough following loss of core geometry and sodium-concrete interactions which you believe

          , have not been adequately analyzed.                         The answer to th-is interrogatory must include a detailed description or explanation of all bases for Intervenors' assertion that such accidents have not been adequately analyzed.

RES PONSE 4(a) Intervenors do not believe any accidents associated with core meltthrough or sodium-concrete interactions have been l adequately analyzed, primarily because CDAs are not treated by i l [ either Staff or Applicant as DBAs. See response to Interrogatory 3-3 of Staf f's First Round of Discovery to NRDC, et al. INTERROGATORY 4(b) Please identify and describe in detail all human errors which can initiate, exacerbate, or interfere with the

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m 12 mitigation of CRBR accidents and which you believe have not been adequately analyzed by Applicants and Staf f. The answer to-this interrogatory must include a detailed description or explanation of all bases for Intervenors' assertion that such i human errors have not been adequately analyzed.

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l RESPO NSE 4(b) See response to Interrogatory 2(g) above. 4 i INTERROGATORY 4(c) Please identify and describe in detail any accident possibilities of greater frequency or consequence than the

        . accident scenarios analyzed by Applicants and Staff.'

i RESPONSE 4(c) Our analysis is incomplete; however, see updated responses to Interrogatories 15, 16, and 21 of the Staff 's Third Set of Interrogatories to NRDC, et al. , and response to Interrogatory 2(b) above. INTERROGATORY 4 4(d) Please furnish a copy of the January 27, 1982, letter from Richard Shikiar to Tromas Cochran to which Intervenors refer on page 28 of their Revised Statement of Contentions and Bases. .

RESPONSE

4(d) This document was provided to Applicants on April 23, 1 1982. 1 i i dbfMine.ifC6 h ,. % A C,: 4.w..c.i w a .4

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5. For Contention 5 (Old 6) i (a) Please identify and describe in detail the population characteristics of the CRBR site which you consider sufficiently unfavorable that an alternative site should be '

selected.

RESPONSE

5(a) Intervenors are referring to comparison of the dose to the maximum exposed individual in the, general public and the population dose commitment at the CRBR site as compared to l other reasonable alternatives. Intervenors also believe that

   . in light of the lessons learned from the TMI acciden~t, in comparing the proposed site with alternatives, the site selection should be weighted heavily in f avor of sites where the maximum exposed individual and the population dose j     commitment due to accidents are substantially smaller due to l     more favorable population and meteorological conditions (i.e.,

l f avor remote sites) . In effect, siting should be treated as l l though it were an independent " barrier" or " safeguard" as part of.tne defense-in-depth approach to reactor safety, as opposed to the historical approach of allowing poor site characteristics to be accommodated by engineering features i associated with the containment; that.is, with the limitation i on siting being defined only by 10 CFR 100 requirements. t l 0=Lt :-= = -_ m- = -

I 14 INTERROGATORY 5(b) Please identify the several alternative sites which you consider to have population densities which are more favorable than the population density of the CRBR. RES PONSE 5(b) Hanford Reservation, Idaho National Engineering Laboratory. Other sites should be included when meteorological characteristics are also factored in (see response to Interrogatory 5(a) above) . Staff has identified several such sites in tne FES. The answer to this question should logically flow from an analysis of alternative CRBR sites on properties

         , owned or controlled by DOE and TVA in an adequate NEPA review of the CRBR by the Staff.

INTERROGATORY 5(c) As to each alternative site identified in response to ) 5(b) above, describe in detail the population characteristics of that alternative site. RES PONSE 9 5(c) Intervenors have not analyzed in detail the population densities or meteorology around these sites. We must rely on an adequate FES. s INTERROGATORY e a 5(d) Please list all "other proposed fuel cycle t facilities" referred to in Contention 5(b) . I 1: iR figkaL-#:%2 3 Om~v y =f'Lw: _ ' ' ~~ 3f yk, _ _ _ _ _? _ N sc T~r' Q

15 RES PONSE 5(d) The only other proposed f uel cycle f acility of which Intervenors are now aware is the Koppers (Tennessee Synfuels Association) Coal-to-Gasoline Project at Oak Ridge. INTERROGATORY

6. For Contention 11 (Old 8)

(a) Please describe in detail the approach which you i believe should be used in establishing guideline values for permissible organ doses. RES PONSE

        ,       6(a)        Intervenors have not made a final decision on which approach should be adopted.                    Intervenors provided their current views on this matter in " Natural Resources Defense Council's l          Response to Objections to Contentions," March 31, 1982, pp.

9-13. On the basis of additional analysis, Intervenors would modify the conclusion on p. 13 of that document in the i following respects. Regarding the ICRP Publication 26 approach, Intervenors currently believe the weighting factors and organ dose limits (" caps" to prevent non-stochastic effects) recommended by EPA should be used rather than those recommended by ICRP 26. (See EPA, " Proposed Federal Radiation Protection Guidance for Occupational Exposure," EPA

520/4-81-003, Jan. 16, 1981, particularly at p. 10.) With 1
regard to the approach favored by Applicants, Intervenors note hd '
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16 that, if Applicants used 40 CFR 190.11 rather than 10 CFR 20 to identify the lung and bone dose " equivalent" to 25 rem whole body, the result would be 25 rem to both lung and bone. This is comparable to tne 30 rem " cap" assumed by EPA to prevent non-stochastic effects. In addition to the above, Intervenors believe that transuranium elements deserve special consideration due to their relatively long half-lives and would use 1 mrad to lung and 3 mrad to the bone from exposure to transuranics as equivalent to 170 mrem to the whole body, based on considerations in EPA, " Proposed Guidance on Dose Limits for

         . Persons Exposed to Transuranium Elements in the Gene'ral Environment," EPA 520/5-77-016, September 1977. See particularly pp. 2, 21, 23.

INTERROGATORY 6(b) Please identify all "important organs" which you believe should be considered in establishing dose guidelines.

RESPONSE

6(b) All organs are considered important under the ICRP 26 , approach. The ICRP 26 approach recognizes some organs as more sensitive than others (e.g., breast, lung, bone marrow) and also considers five "other organs" with the highest doses. See i EPA 520/4-81-003, p. 10 and response to Interrogatory-6(a) above. m l l JM s . ~e .w wa, .,. . .. - inai

1 1 17 i INTERROGATORY 6(c) Identify and describe in detail all "new knowledge" which you believe should be considered in establishing dose guidelines.

RESPONSE

 .                             6(c)    Tne. primary documents Intervenors currently believe should be considered are ICRP 2 6, ICRP 3 0, 4 0 CFR 19 0.10 and EPA 520/4-77-016.

! INTERROGATORY 6(d) Please explain specifically the oasis for your

                      -  assertion that Applicants and Staf f have not adequat'ely j                         assessed the residual risks associated with genetic effects I                          from radiation e::posure in compliance with existing NRC

. standards. The answer to this interrogatory must include a i detailed description or explanation of Intervenors' view as to why the assessment is not adequate. RES PONSE , 6(d) Applicants and Staff have not demonstrated that i j proposed radiation protection procedures, which do not limit l l exposures of workers in the child-bearing age to an amount that is less than that permitted for ~ older workers (e.g., those over 45 years of age) , are consistent with the ALARA principle. See NRDC, " Radiation Standards for Occupational Whole Body Exposure," Thomas B. Cochran and Arthur R. Tamplin, Sept. 25, l k ' Y [ @ 'q g g g OM1'd '[,.  % p,g $ 3 -4_w y g _'g_

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i 18 4 1975. See also Response to Interrogatory 6(e) below; Updated Responses to Interrogatories 4-7 under Contention 8 (New 11) of Staff's Fourth Set of Interrogatoties to NRDC, et al; and part

 ;                         (3) of Updated Response to Interrogatory 2 under Contention 9 (New 6) of Staff 's Fourth Set of Interrogatories to NRDC, et al.

INTERROGATORY 6(e) Please identify and describe in detail the basis for your assertion that Applicants and Staf f have not adequately assessed the residual risks associated with induction of cancer from the exposure of plant employees and the public in compliance with existing NRC standards. - RES PONSE 6(e) See Response to Interrogatory 6(d) above. In addition, because Staff and Applicants do not report risk, but

only dose, the discussion fails to adequately characterize the widely divergent views of experts regarding risks, e.g., the l views of BEIR III, Edward Radford, Karl Z. Morgan, and John i
Gofman. Finally, Contention ll(d) is part of the basis for this assertion. See also updated response to Interrogatory 8 l under Contention 8 ( New 11) of the Staff 's Fourth Se t of i

Interrogatories to Intervenors. I i

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19 INTERROGATORY

              ~7 . For Contention 8 (Old 14)

(a) Please identify and describe in detail the unavoidable adverse environmental effects associated with the decommissioning of the CRBR which you believe nave not been ' adequately analyzed. The answer to this interrogatory must include a detailed description or explanation of the specific 1 elements of the analyses which you assert are inadequate and the bases for that assertion. RES PONSE 7(a) Intervenors know of no practical means of preventing-

            . the radioactive decay of unstable isotopes produced ~in reactor components through neutron activation during the operation of a reactor, hence the term " unavoidable."          Intervenors are aware of four principal modes of decommissioning:              dismantlement, entombment, mothballing, and, possibly in the future, disposal at sea. Each presents " adverse environmental effects,"

although these ef fects are not necessarily or always the same. The decommissioning method chosen and its cost will depend in part on the nature of the neutron activation products presented by the reactor operation. Intervenors in Contention 8 claim that a systematic analysis of all neutron activation production for CRBR has not been performed;. a comprehensive analysis of I CRBR decommissioning analogous to NUREG/CR-0570 (1980) for boiling water reactors, or NUREG/CR-1756 (1982) for research reactors, has not been performed; there is no showing l f I l l

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a 1 20 f of which aspects of the EIS on Decommissioning of Nuclear f Facilities (NUREG-0586, 1981) are applicable, and the discussion at pp. 10-3, 4 in the FES is superficial and out of date. With regard to further specificity as to the elements of ) the analysis that are deficient, we remind Applicants that it

is not Intervenors' responsibility to perform Applicants' or Staff's work in preparing an adequate EIS.

{ See also Harwood, e t al. , "The Cost of Tu rning It Of f," Environment 18, Dec. 19 76, pp . 17-2 6, Scie nce , 215 (5 March l 1982), pp. 1217-1219; Stephens, e t al. , " Trace Elements in

               , Reactor Steels:              Implications for Decommissioning," Cornell Univ., Aug. 1977, published in Nuclear Enoineering Design (circa 1978) .

i f INTERROGATORY 7(b) Please identify and describe in detail the costs associated with the decommissioned CRBR which you assert are not adequately assessed in the NEPA cost / benefit balancing of i the CRBR. The answer to this interrogatory must include a i detailed description or explanation of the specific elements of

the analysis which you assert are inadequate and the bases for that assertion. s RES PONSE 7(b) Tnose identifed in $10. 2. 4. 3 o f t he FES. See also j response to Interrogatory 7(a) above.

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21 INTERROGATORY 7(c) Please state whether it is your view that the CRBR FES is inadequate due in part to recently discovered omissions in regard to the subject matter of contention 8, and, if so, identify and describe all such "recently discovered omissions."

RESPONSE

7(c) Yes: Analysis of Nickel-59 and Niobium 94. The FES is also inadequate for reasons stated in response to 7(a) above. INTERROGATORY 7(d) Please state whether it is your view that the CRBR

      . FES is inadequate for reasons other than "recently d'iscovered omissions" and, if so, identify and descrioe all such inadequacies in the CRBR FES.

RESPO NSE 7(d) Yes. See response to Interrogatory 7(a) above. INTERROGATORY 7(e) Please identify specifically any and all neutron activation products, ocher than nickel 59-and niobium 94, which i you assert have not been adequately analyzed for the decommissioning of the CRBR and/or which you believe must be so I analyzed. - l l I l l l i sNd ' L 1. an 24 w ;. h%- :s a.:+ , n - 2G&

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22 RES PONSE 7(e) There is no hidden agenda here. If there are other omissions, they can be expected to be discovered through a systematic analysis of all neutron activation products for CRBR. None have been adequately analyzed for reasons stated in response to 7(a) above. Respectfully submitted, _L-

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Earbara A. Finamore S. Jacob Scherr Natural Resources -Defense Council, Inc. 1725 Eye Street, NW Washington, D.C. 20006 (202)223-8210 Attorneys for Intervenors Natural Resources Defense Council, Inc., and the Sierra Club May 6, 1982 Wa sni ng to n , D.C. I I i l s l l I i i

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4 BEFORE THE UNITED STATES j NUCLEAR REGULATORY COMMISSION i ATOMIC SAFETY AND LICENSING BOARD

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i In The Matter of )

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4 UNITED STATES DEPARTMENT OF ENERGY ) PROJECT. MANAGEMENT CORPORATION ) Docket No. 50-537 TENNESSEE VALLEY AUTHORITY ) ' ) .

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!                                    Clinch River Breeder Reactor Plant                                                        )

! ) i, APFIDAVIT OF DR. THOMAS B. COCHRAN ] j I, Dr. Thomas B. Cochran, being duly sworn, depose and say: ! 'l. I am employed as a Senior _ Staff Scientist by the Natural Resources Defense Council, Inc., and, as such, I am duly authorized to execute tne foregoing answers to interrogatories. 2.. The foregoing answers are true and-correct-to the best of my knowledge and belief. Dr. Thomas B. Cochran.

s. Subscribed and sworn to before me
                                    'this'Sth day of May 1982.
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      -                                                                                                 October'1, 1981 i

RESUME Thomas B. Cochran, Ph.D. Business Address: Natural Resources Defense Council, Inc. i 1725 I Street, NW, Suite 600 Washington, D.C. 20006 (202)223-8210 Home Address: 4836 North 30th Street Arlington, VA 22207 (703)532-1044 EMPLOYMENT HISTORY i April 1973-precant: Natural Resources Defense Council, Inc. Senior Staff Scientist, focusing on national energy R&D policy, principally nuclear energy issues, the breeder reactor, plutonium recycle, nuclear weapons proliferation, safeguards,

,                     and radiation exposure standards.                                 Consultant to the U.S.

Department of Energy (DOE) on nuclear nonproliferat. ion and nuclear R&D strategy; consultant to the Comptroller General on ' (a) U.S. and international controls over the peaceful uses of ' nuclear energy, (b) Advanced Nuclear Technologies, and (c) U.S. Liquid Metal Fast Breeder Reactor Program; consultant to the Office of Technology Assessment (OTA) ; Member of DOE's Energy j Research Advisory Board, DOE's Nonprolifreation Advisory Panel, i OTA's Advisory Panel on Nuclear Prolifreation and Safeguards, l the Nuclear Task Group of OTA's Analyses of the ERDA Plan and Program, and OTA's Gas Curtailment Study Review Panel. Consultant' to Governor of Lcwer Saxony, West Germany, to serve as an Inter-l national Expert in the Review of the Gorleben Nuclear Fuel Cycle Center. Served as a member of ERDA's LMFBR Review Steering . Committee, the National Academy of Sciences' Panel on Strategy for Developing Nuclear Merchant Ships, the Task Force on Energy Conversion Research and Development of the Federal Power Survey, j the United Nations' Environment Programme's International Panel of Experts on Energy and the Environment, the National Council of Churches' Energy Study Panel and the World Council of Churches Consultation on Ecumenical Concerns in Relation tc Nuclear Energy. Also served as a consultant-to Resources for the Future ! and numerous environmental organizations. Testified before Congress and federal agency hearings on numerous occasions, including testimony before the' Joint Committee on Atomic Energy, the House Committee on Interior and Insular Affairs, the Joint Economic Committee, the House Committee on Small Busipess, and the Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards. i i

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   /
 . Thomas'B. Cochran Page Two June 1971-April 1973:     Resources for the Future, Inc.

Washington, D.C. Senior Research Associate, Quality of the Environment Program. Studying environmental effects of the U.S. civilian nuclear power industry, residuals management in the nuclear fuel cycle, liquid metal fast breeder reactor program, national energy policy, and radiation standards. Wrote a book, The Liquid Metal Fast Breeder Reactor: An Environmental and Economic Critique. 1969-1981: Litton Mellonics Division, Scientific Support Laboratory Fort Ord. California Modeling and Simulation Group Supervisor. Supervised the activities of 10 operation research analysts engaged in military research pertinent to the evaluation of proposed U.S. Army concepts and material by U.S. Army CDCEC. 1967-1969: U.S. Naval Postgraduate School Monterey, California Lt-USNR, Active Duty; Assistant Professor of Physics; Radiation Safety Committee; part-time research involving computer studies of synchrotron radiation production in beam transport systems at

  • Stanfard Linear Accelerator, Stanford, California.

EDUCATION Summer 1969: University of Colorado, Boulder. Postdoctorate. Summer Institute of Theoretical Physics. 1965-1967: Vanderbilt University, Nashville, TN. Doctorate. Major: Physics. Minor: Mathematics. Research in high energy (bubble chamber) physics. NASA Fellowship. Guest Research Associate in Physics Department at Brookhaven National Laboratory, Upton, NY, studying synchrotron radiation shielding problems. 1962-1965: vanderbilt University. MS degree in Physics. l Research in radiation chemistry; AEC Health Physics Fellow; applied health physics training, Oak Ridge National Laboratory; Vanderbilt University Campus Radiation Safety Officer. 1958-1962: Vanderbilt University. BE degree in Electrical ( Engineering, cum laude. NROTC. l I PROFESSIONAL AFFILIATIONS American Physical Society Health Physics Society Macrican Nuclear Society Sigma Xi PERSONAL Age: 40. Birth date: 18 November 1940. Birth place: Wash. DC. Wife: Carol J. Cochran. Two children. i

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w CERTIFICATE OF SERVICE 1) I hereby certify that copies of RESPONSE OFEINTERVENOR3, NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUE, TO NRC STAFF FIRST ROUND OF DISCOVERY TO NRDC, ET AL., and RESPONSE OF NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB TO APPLICANTS' FOURTH SET OF INTERROGATORIES were

           . served this 6th day of May 1982 on the following:
  • Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway 5

Bethesda, Maryland 20814

  • Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway -

Bethesda, Maryland 20814

  • Daniel Swanson, Esquire Stuart Treby, Esquire Bradley W. Jones, Esquire Of fice Of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 773 5 Old Georgetown Road Bethesda, Maryland 20814
  • Atomic Safety & Licensing Appeal Board U.S. .;aclear Regulatory Commission Washington, D.C. 20555
  • Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
  • Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission
Wasnington, D.C. 20555
(3 copies)
   '"            ~ ~ " '

i .

  • R. Tenney Johnson, Esquire Leon Silverstrom, Esquire Warren'E.-Bergoholz, Jr., Esquire Micnael D. Oldak, Esquire L.:Dow Davis, Esquire Of fice of General Counsel ~

U. S . Department of Energy 1000 Independence Ave., S.W. ' Washington, D.C. 20585

  • George L. Edgar, Esquire Irvin N. Shapell, Esquire Thomas A. Schmutz, Esquire 4

Gregg A. Day, Esquire

Frank K. Peterson, Esquire Morga n , Lewis & Bockius 1800 M Street, N.W.

j Washington, D.C. 20036 i 4 Dr. Cadet H. Hand, Jr. ! Director . Bodega Marine Laboratory University of California P.O. Box 247 l Bodega Bay, California 94923 i He r be r t S . Sanger, Jr., Esquire

;                                           Lewis E. Wallace, Esquire j                                            James F. Burger, Esquire W. Walker LaRoche, Esquire Edwa rd J. Vigluicci i                                            Office of the General Counsel
Tennessee Valley Authority

! 400 Commerce Avenue Knoxville, Tennessee 37902 William M. Leech, Jr., Esquire Attorney General William B. Hubbard, Esquire l Chief Deputy Attorney General i Lee Breckenridge, Esquire i Assistant Attorney General State of Tennessee ! Office of the Attorney General i 450 James Robertson Parkway l Nashville, Tennessee 37219 4 1 4 i l

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Lawson McGhee Public Library 500 West Churen Street

                                   -Knoxville, Tennessee 37902 William E. Lantrip, Esquire l                                    City Attorney Municipal 3uilding P.O. Box 1 Oak Ridge, Tennessee 37830 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Mr. Joe H. Walker.

401 Roane Street Harriman, Tennessee 37748 Commissioner James Cotham Tennessee Department of Economic

and Community Development -

) Andrew Jackson Building, Suite 1007 j Nashville, Tennessee 32219

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                                                  &arbara A. Finamore
  • Denotes hand delivery.

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