ML20052B625

Update to 770316 Responses to NRDC & Sierra Club 760813 Tenth Set of Interrogatories.Certificate of Svc Encl

ML20052B625
Person / Time
Site:	Clinch River
Issue date:	04/29/1982
From:	Longenecker J JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
To:	National Resources Defense Council, Sierra Club
References
NUDOCS 8205030384
Download: ML20052B625 (10)

Text

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/ 4/29/82 s em RECEIVEQ; -

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"IN UNITED STATES 6 NUCLEAR REGULATORY COMMISSION

)

In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

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

)

(Clinch River Breeder Reactor )

Plant) )

)

APPLICANTS' UPDATED i RESPONSE TO INTERVENORS',

NATURAL RESOURCES DEFENSE COUNCIL, INC.

AND SIERRA CLUB, TENTH SET OF INTERROGATORIES TO THE APPLICANTS Pursuant to 10 CFR S 2.740b. , and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy, Project Management Corporation, and the Tennessee Valley Authority (the Applicants), hereby file their updated responses to Intervenors ' , Natural Resources Defense Council, Inc. , and t

the Sierra Club, Tenth Set of Interrogatories to the  !

Applicants, dated Augus t 13, 1976.- /

• / Applicants previously responded to these interroga-tories on March 16, 1977. Applicants have prepared these updated responses to establish a current base cf information for the CRBRP for the purpose of expediting these proceedings. Accordingly, in prcviding these l responses, Applicants do not concede that the informa-tion contained therein admissible-in or necessary to a Continued g6od 820503o384 69

e Answers to General Questions (a) - (f)

(a) Provide the direct answer to the question.

ANSWER: See the direct answers below under heading " ANSWER".

(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 there-4 of, at Applicants ' option, a copy of such j document and study may be attached to the answer.

ANSWER: See the direct answers below under heading " DOCUMENTS".

(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 answer.

, decision in the LWA proceeding. Applicants have not furnished copies of or made available for inspection

! and copying those documents referenced in this response which were previously referenced and made available pursuant to the Applicants' previous responses. Docu-I ments referenced for the first time in this updated ,

response will be made available upon request. General questions and responses follow the protocol agreed upon ,

by the parties and attached to Mr. Greenberg's March 8,  ;

1982 letter to Counsel for PMC.

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ANSWER: Unless otherwise indicated below in regard to the answer under the heading

" DOCUMENTS"; none.

(d) Identify by name, title and affiliation the primary Applicant employee (s) or consultant (s) who provided the answer to the question.

ANSWER: See the attached affidavits.

(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.

ANSWER: If not in Section 1.5 of the PSAR and the direct answer below; none.

(f) Identify the expert (s) if any, which Appli-cants intend to have testify on the subject

matter questioned, and state the qualifica-tions 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 determintd that no expert will testify, as c long as such answer provides reasonable notice to Intervenors.

ANSWER: Applicants have not yet identified the expert (s) in question.

Answers to Specific Questions Interro gato ry .

V9. What is meant by the phrase:

The best interest of the public is served by the Clinch River Breeder Reactor Plant as a demonstration plant to show the safety, economic and environmental advantages of the LMFBR technology on page 3 of the letter.

l Answer.

! The complete sentence referred to in this question from the July 14,.1976, letter from L. W. Caffey to R. Boyd reads as follows:

"It is the Project's concern that the imposition of unrealistic assessments could lead to design modifications that

1 are not in the best interest of the public as served by the Clinch River Breeder Reactor Plant as a demonstration plant to show the safety, economic, and environmental advantages of the LMFBR technology."

When read in context with the rest of this sentence and the preceding three sentences in which the Applicants indicated that the technical bases for a 1200Mw energetic event are not fully understood, it becomes apparent that in this passage the Applicants are suggesting that NRC's analytical techniques and assumptions regarding such a disruptive event are unduly conservative and should be revised to reflect a more reasonable estimate of the energetics associated with such a disruptive event. Imposi-tion of unrealistic assessments leading to additional unnecessary design requirements or design features results in no real increase in overall plant safety while at the same time adds to the cost and complexity of the CRBRP.

Since there would be no increase in the overall protection afforded to the public health and safety or enhancement of l

the environment associated with these design features, the addition of cost and complexity would be inconsistent with l the demonstration objectives of CRBRP. If these design l

l features were to be imposed, the Applicants believe, there-i fore, that the best interest of the public would not be

! served.

Interrogatory. f V 10. Describe in detail why the CRBR would not serve the demonstration function if its design were overly conservative.

i Answer.

As stated in No. 9., the use of unrealistic l assessments which lead to no real increase in overall plant safety adds cost and complexity without a compensating bene-fit. Therefore, addition of features or requirements which have no real safety advantage might impede the demonstration objectives of the CRBRP. ,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS 0N In the matter of ,)

Department of Energy ,)

DOCKET NO. 50-537 PROJECT MANAGEMENT CORPORATION and,)

TENNESSEE VALLEY AUTHORITY ,)

AFFIDAVIT OF John R. Longenecker, being duly sworn, deposes and says as follows:

1. That he is employed as Manager, Licensing and Environmental ,

Coordination, Office of Nuclear Energy, U.S. Department of Energy, and that he is duly authorized to update the replies to Items 6 and 8 in the first set, items V.9 and V.10 in the tenth set and items 1, 2, and 3 in the fourteenth set of interrogatories propounded by the Natural Resources Defense Council, et. al.

2. That the above-mentioned and attached answers are true and correct to the best of his knowledge and belief.

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('T y'h.d\.cu.w.a b f Signature SUBSCRIBED and SWORN to before me this /? day of // C ,> C , 1982.

/.. . . e - .l  ;

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Notary ~Public My Commission expires , 19 . l l

1 PATRICIA G. CILfMBERG NOTARY PU9tfC ? *'5 CF MARytmg l My Cqsr,iwq, r .c, gy 3, ,pn

UNITED STATES OF AMERICA 4-NUCLEAR REGULATORY COMMISSION 1

)

In the Matter of )

)

J UNITED STATES DEPARTMENT OF ENERGY )

)

PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) ) ,

)

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

• Marshall E. Miller, Esquire Chairman 2 Atomic Safety & Licensing Board

U. S. Nuclear Regulatory Commission Washington, D. C. 20545 Dr. Cadet H. Hand, Jr.

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

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

• Daniel Swanson, Esquire

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

O

-2.

• Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545

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

• Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (3 copies)

William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)

• • Dr. Thomas Cochran Barbara A. Finamore, Esquire

. Natural Resources Defense Council l 1725 Eye Street, N. W., Suite 600 l

Washington, D. C. 20006 (2 copies)

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

O Lawson McGhee Public Library 500 West Church Street

. Knoxville, Tennessee 37902 William E. Lantrip, Esq.

Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq.

Warren E. Bergholz, Jr., Esq.

U. S. Department of Energy 1000 Independence Ave., S. W.

Room 6-B-256, Forrestal Building

, Washington, D. C. 20585 (2 copies) l

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

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A Geor M . Edg V Attorney for Proj ect Management Corporation DATED: April 29, 1982 l

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

• • / Denotes hand delivery to indicated address.

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